Disputes with a supervisor can often make your work environment untenable.  But what is an employer’s legal responsibility when an employee claims that working for a particular supervisor is so stressful that the employee is disabled and needs to be reassigned as a reasonable accommodation? Recently, in Higgins-Williams v. Sutter Medical Foundation, a California appellate court held that an employees inability to work with a particular supervisor is not a disability.

The plaintiff Michaelin Higgins-Williams was a clinical assistant and reported to her personal physician that she was stressed out due to her interactions with a particular manager. She was diagnosed with adjustment disorder with anxiety and took stress leave for 30 days. Upon return, she received a negative performance evaluation and had additional conflicts with the same manager.

She requested accommodations, including being transferred to a different department and being granted additional leave.  Her employer granted the additional leave for more than a year and but eventually terminated her without allowing her to transfer. She then sued for disability discrimination.

The court granted summary judgment for her employer finding that the plaintiff was not disabled because of the inability to work under a particular supervisor because anxiety and stress related only to a particular supervisor, is not a mental disability under FEHA.