The Americans with Disabilities Act Amendments Act expanded the definition of a disability so much that just about anything’s considered a disability these days. Just not what this employee was trying to sell to a California court.
Meet Michaelin Higgins-Williams. She was a clinical assistant at Sutter Medical Foundation.
About three years into her employment, Higgins-Williams visited her doctor complaining about stress caused by interactions with her manager and Sutter’s HR team.
The doctor diagnosed her with adjustment disorder with anxiety.
As a result of the diagnosis, Sutter granted Higgins-Williams a stress/disability-related leave of absence under California’s Moore-Brown-Roberti Family Rights Act and the FMLA.
When Higgins-Williams exhausted her leave allotment, she returned to work. But all was not rosy.
She quickly received a negative performance evaluation from her manager. Higgins-Williams also claimed that she began to be singled out by her manager for performance problems.
About a month after she returned to work, Higgins-Williams requested additional time off as an accommodation for her disability. Sutter approved additional leave for her.
Shortly before Higgins-Williams was scheduled to return to work, her doctor submitted a status report to Sutter stating that Higgins-Williams needed to be transferred to another department and be supervised by a different manager. The doctor also requested additional leave for Higgins-Williams, which was granted.
Roughly two months after that, Higgins-Williams’ doctor requested an additional month of leave. The doctor also requested that following the additional month of leave, Higgins-Williams be placed in a light duty position.
After this request, Sutter informed Higgins-Williams that:
- her doctor didn’t provide any info as to when she’d be able to return to her position
- there was no information to support a conclusion that additional leave as an accommodation would help her return to her position, and
- without either of those two pieces of info Higgins-Williams would be terminated.
When the doctor failed to provide that info, Higgins-Williams was fired.
Following her termination, Higgins-Williams sued claiming disability discrimination, failure to engage in the interactive process, and failure to provide reasonable accommodation under California’s Fair Employment and Housing Act (FEHA).
FEHA is a law that closely mirrors the ADA in terms of the protections it provides to disabled individuals. The FEHA, however, is much more lenient (in employees’ favor) than the ADA when it comes to determining what’s a disability and what isn’t.
For Higgins-Williams to have a case, the court — California’s 3rd District Court of Appeal — first needed to determine whether or not she was disabled.
“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 disability under FEHA.”
This ruling has to be music to employers’ ears. Just when it was starting to look like courts would allow anything to be considered a disability for which employers need to seek reasonable accommodations, this court draws the line.
The court said an inability to work under a particular supervisor didn’t quit reach the relatively low bar an impairment must reach to be considered a disability. The court even surmised that simply having an inability to do a job could be enough to qualify someone as “disabled,” but Higgins-Williams wasn’t plagued by an inability to perform her job.
So her lawsuit was tossed.
Cite: Higgins-Williams v. Sutter Medical Foundation