Supervisor Stressing Out Employee Is Not A Disability
Court Holds Adjustment Disorder Triggered by Stress at Work Is Not a Disability
A California Appeals Court in April held in Higgins-Williams v. Sutter Medical Foundation that an employee diagnosed with an adjustment disorder triggered by stress caused by her supervisor’s standard management of her job performance is not disabled under the California Fair Employment and Housing Act. In doing so, the court resisted the current trend of expanding protections of employees unable to work due to physical or mental disabillities.
Employed as a clinical assistant, Michaelin Higgins-Williams reported to her personal (non-work) treating physician that she was stressed because of interactions at work with human resources and her manager. In leave paperwork submitted to her employer, her physician reported her condition as “stress when dealing with her Human Resources and her manager.” After one of her leave requests was denied and she was instead terminated, she sued for disability discrimination and failure to accommodate her disability in violation of the FEHA.
The court affirmed summary judgment for her employer on the ground she was not disabled as a matter of law. The court noted a previous case had held a mental condition that prevented an employee from working under a particular supervisor or performing one particular job did not constitute a disability under FEHA: Hobson v. Raychem Corp. Hobson applied the now-discarded standard that a medical condition must substantially limit a major life activity to qualify as a disability; the current standard under the FEHA is that a medical condition need only limit a major life activity, whether or not that limitation is substantial. The Appeals Court held Hobson remains good law on the point that inability to work under a specific supervisor because of anxiety and stress related to the supervisor’s standard job performance supervision does not constitute a mental disability under FEHA. The Court maintained this decision, even though the supervisor allegedly singled Higgins-Williams out for negative treatment and grabbed her arm and yelled at her.
Ordinarily a physical or mental condition that limits an employee’s ability to work will be considered a disability requiring reasonable accommodation, and employers should attempt to accommodate employees with such conditions wherever possible. This case places a welcome boundary around employee disability claims. Thankfully, an employee cannot claim he or she is disabled because their supervisor stresses them.