Managing interpersonal conflict in the workplace is always a delicate and time-consuming duty for managers and Human Resources personnel.  But what happens when an employee claims that he or she suffers from a disability due to stress from working with a specific manager or supervisor?  Must the employer accommodate the alleged disability by transferring the employee (or the supervisor!) to another role within the company?  According to a recent opinion from the California Court of Appeals, Higgins-Williams v. Sutter Medical Foundation, 237 Cal. App. 4th 78 (3d Dist. 2015), the answer is No.

Michaelin Higgins-Williams was a clinical assistant at Sutter Medical Foundation.  Initially hired in 2007, in June 2010 Higgins-Williams reported to her treating physician that she was experiencing stress because of interactions with her manager and with human resources.  Her physician diagnosed her as having adjustment disorder with anxiety and Higgins-Williams was granted a stress-related disability leave of absence from work under the California Family Rights Act (CFRA) and the federal Family Medical Leave Act (FMLA).  At the expiration of her entitlement to leave under each act, Higgins-Williams returned to work and received a negative performance review.  Following this review, Higgins-Williams claimed that she was being singled out for negative treatment and, after a September 2010 encounter in which her supervisor grabbed her arm, Higgins-Williams had a panic attack, left work and did not return.

Following these events, Higgins-Williams requested a leave of absence, which her employer granted.  After an additional leave of absence that extended into January 2011, her treating physician stated that she could not return to work until March 2011 and then only on light duty.  Sutter Medical Foundation requested additional information from Higgins-Williams and informed her that if she did not comply with the request, her employment would be terminated on February 1, 2011.  Higgins-Williams responded that she did not feel she could return to work on February 1 but that she would try to return on March 1 instead.  Sutter terminated Higgins-Williams’ employment as of February 1, 2011.

Higgins-Williams filed suit, claiming that Sutter violated the California Fair Housing and Employment Act (FEHA) by discriminating against a person with a disability, failing to engage in the interactive process and failing to make reasonable accommodations, retaliating against her on the basis of her disability, and wrongfully terminating her on the basis of her disability.  The trial court granted Sutter’s motion for summary judgment on each claim, holding that Higgins-Williams failed to demonstrate that she suffered from a mental disability as defined by FEHA.

On appeal, the court upheld the trial court’s decision and held that an employee’s inability to work under a particular supervisor because of anxiety and stress related to the supervisor’s oversight of the employee’s job performance did not constitute a disability under FEHA.  Citing Hobson v. Raychem Corp., 73 Cal. App. 4th 614 (1st Dist. 1999), another Court of Appeals decision in which an employee’s inability to work under a specific supervisor was found not to qualify as a disability under FEHA, the court of appeals stated that Higgins-Williams’ purported disability was the “inability … to work under a particular supervisor” that Hobson held was not a disability under FEHA.  Because she was unable to demonstrate the existence of a disability under FEHA, her claims for discrimination, retaliation and wrongful termination based on that “disability” all failed.

While there is no one-size-fits-all approach to managing interpersonal conflict or requests for accommodation, this case provides useful guidance for employers struggling to determine just what constitutes a disability and how to conduct the interactive process required when an employee requests an accommodation based on an alleged disability.