Court Rules Stress and Anxiety Caused by Manager Does Not Constitute Legally Protected Disability

June 8, 2015 by Christopher Hammer

Both California and Federal law protects disabled employees from discrimination, and requires employers to reasonably accommodate disabled workers.

One threshold question in all disability accommodation claims is whether the alleged disability is one that is protected under the law.  Disabilities protected by the law include not just physical disabilities, but mental disabilities as well.  A qualifying mental disability under the law includes any mental or psychological disorder, such as an emotional or mental illness that limits a major life activity, including physical, mental and social activities, such as working.

Relying on an earlier California decision, a California Court of Appeals recently held that a mental disability caused by the standard oversight of an employee’s job performance by a supervisor is not a legally recognized mental disability for purposes of California’s disability discrimination law. (Higgins-Williams v. Sutter Medical Foundation, May 26, 2015.)  In Higgins-Williams, the plaintiff’s doctor diagnosed her as having an adjustment disorder with anxiety, and reported that plaintiff’s disabling condition was caused by stress when dealing with her manager.  The Court concluded that the inability to work under a particular supervisor does not constitute a legally-recognized disability.

It is important to recognize that the Court’s decision did not exclude all anxiety related mental disabilities caused by a supervisor from the law’s protection.  Significantly, the Court’s decision relied on employer conduct the Court considered “standard supervisorial oversight”, and left open the possibility that anxiety caused by non-standard conduct could support a claim of mental disability discrimination under the law.

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