In Miller v. California Department of Corrections & Rehabilitation (CDCR), 105 Cal. App. 5th 261 (2024), the California Court of Appeal addressed critical issues regarding disability discrimination and the employer’s obligation to provide reasonable accommodations under the California Fair Employment and Housing Act (FEHA). The ruling highlights the duty of employers to engage in good faith with employees experiencing disabilities and has significant implications for workplace discrimination law.
Janet Miller, a long-time employee of the CDCR, developed a chronic medical condition that substantially limited her ability to perform certain physical tasks required by her job. After her diagnosis, Miller requested reasonable accommodations, including modified duties and ergonomic adjustments. While the CDCR initially provided some accommodations, Miller alleged that the department later failed to engage in a meaningful interactive process and ultimately assigned her tasks that aggravated her condition, forcing her to take medical leave.
Miller filed a lawsuit against the CDCR, alleging violations of FEHA, including failure to provide reasonable accommodations, failure to engage in the interactive process, and retaliation for requesting accommodations. The trial court ruled in favor of the CDCR, finding that Miller had not sufficiently proven her claims. Miller appealed, challenging the lower court’s interpretation of FEHA’s requirements.
The California Court of Appeal reversed the trial court’s decision, emphasizing the stringent obligations placed on employers under FEHA to address disability-related requests. The court’s analysis centered on three key issues:
- Reasonable Accommodations: The court reiterated that FEHA requires employers to make reasonable accommodations for employees with disabilities, unless doing so would impose an undue hardship. In Miller’s case, the evidence showed that the CDCR failed to provide consistent accommodations that would have allowed her to perform her essential job functions. The court highlighted that employers cannot unilaterally withdraw accommodations without justification.
- Interactive Process: The court found that the CDCR failed to fulfill its duty to engage in a timely, good-faith interactive process to explore accommodations. The interactive process is a collaborative effort between employer and employee to identify potential solutions. The court noted that the CDCR’s lack of meaningful communication with Miller and its apparent disregard for her medical restrictions constituted a violation of FEHA.
- Retaliation: The court also addressed Miller’s retaliation claim, concluding that adverse actions taken against her—including assigning her physically demanding tasks despite her medical restrictions—could reasonably be interpreted as retaliation for asserting her rights under FEHA.
The Court of Appeal ruled in favor of Miller, holding that the CDCR had violated FEHA by failing to provide reasonable accommodations and neglecting its obligation to engage in the interactive process. The court’s decision underscores the need for employers to take employee disability claims seriously and engage proactively in addressing accommodation requests.
This ruling carries significant implications for employers in California. It reinforces that FEHA imposes a proactive duty to collaborate with employees in determining accommodations and that failure to do so may result in substantial legal liability. Employers must ensure that accommodations are not only offered but also maintained consistently unless there is a legitimate reason to modify or withdraw them.
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