Higgins-Williams v. Sutter Medical Found.
Annotate this CaseIn September 2007, defendant Sutter Medical Foundation hired plaintiff Michaelin Higgins-Williams as a clinical assistant in Sutter's Shared Services Department. In June 2010, plaintiff reported to her treating physician, Alexander Chen, M.D., that she was stressed because of interactions at work with human resources and her manager. Dr. Chen diagnosed plaintiff as having adjustment disorder with anxiety. Based on Dr. Chen's diagnosis, Sutter granted plaintiff a stress-related (disability) leave of absence from work under the CFRA and the federal Family and Medical Leave Act of 1993. Plaintiff exhausted her available CFRA and FMLA leave entitlements when she took the leave of absence from June 28 through August 2, 2010. When plaintiff returned to work on August 3, 2010, she received a negative performance evaluation from a supervisor, which was also signed by regional manager; this was plaintiff's only negative evaluation while employed at Sutter. According to plaintiff, her supervisor inaccurately accused plaintiff of being irresponsible in the care of her identification badge. And on that same day, the regional manager grabbed plaintiff's arm and yelled at her, after which plaintiff suffered a panic attack, left work, and never returned. In mid-September 2010, plaintiff submitted to Sutter a disability accommodation request form, requesting a transfer to a different department (for "forever"), a schedule of 9:00 a.m. to 6:00 p.m., and, pursuant to Dr. Chen's recommendation, a leave of absence from September 9 through October 31, 2010. Sutter granted this requested leave of absence, and two additional leave periods based on Dr. Chen's recommendations. On January 24, 2011, Sutter informed plaintiff :(1) that Dr. Chen had stated on January 6, 2011, that plaintiff could not return to work then, but that plaintiff wanted to return on March 1, 2011, on light duty in the Connecting to Work Program; (2) that Dr. Chen did not provide any information as to if or when plaintiff would be able to return to her clinical assistant position; (3) that there was no information to support a conclusion that additional leave as an accommodation would effectuate plaintiff's return as a clinical assistant; and (4) that if plaintiff did not provide such information by January 31, 2011, her employment would be terminated February 1, 2011. On January 28, 2011, Dr. Chen informed Sutter that plaintiff was not medically cleared to return to work at that point, and that plaintiff would continue her regimen of psychotherapy and medications. Sutter terminated plaintiff February 1, 2011. Plaintiff sued for wrongful termination, and the trial court granted summary judgment in favor of Sutter. The Court of Appeal affirmed, largely because plaintiff's alleged disability, "disability—an inability to work under a particular supervisor because of anxiety and stress related to the supervisor's standard oversight of job performance," was not a disability recognized in California's Fair Employment and Housing Act.
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