In Higgins-Williams v. Sutter Med. Found. (2015) 237 Cal.App. 78, Ms. Higgins-Williams worked as a clinical assistant in Sutter’s Shared Services Department and reported to her treating physician that she was stressed because of interactions at work with human resources and her manager. Her physician diagnosed Higgins-Williams with “adjustment disorder with anxiety,” and Sutter granted her a stress-related leave of absence of slightly more than 30 days. After her return she received a negative performance evaluation and had additional conflicts with her manager. She thus, sought a disability accommodation transfer to a different department and an additional leave of absence.
Following over a year of additional leaves of absence, Sutter terminated Higgins-Williams’ employment. Higgins-Williams sued alleging disability discrimination, wrongful termination and related claims.
The trial court granted Sutter’s motion for summary judgment, and the Court of Appeal affirmed on the ground that Higgins-Williams was not disabled. The court ruled that:
“an employee’s inability to work under a particular supervisor because of anxiety and stress related to the supervisor’s standard oversight of the employee’s job performance does not constitute a mental disability under FEHA.”
Since Higgins-Williams had not indicated to Sutter when or if she could return to work, her claim for violation of the federal Family and Medical Leave Act (FMLA) and the California Family Rights Act (CFRA) was also dismissed.
The Higgins-Williams case is the first in California that permits the employer to look at the reason a leave request is made and addresses the pre-requisites an employee must meet to maintain an action under the FMLA and CFRA when the employee is not further accommodated or reinstated. As an employer it has become virtually essential that leave requests, requests for accommodations, reinstatement requests and employee terminations be considered carefully in order to make certain there are no laws violated.
The information presented is not intended to be, and does not constitute, “legal advice.” Because each situation varies, and only brief summary information is provided here, you should not use this information as a basis for action unless you have independently verified with your own counsel that it applies to your particular situation.
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