California: Voluntarily Resigning in an “Altered Mental State” is Not a Disability Protected from Discrimination

This specific set of circumstances arose from Ruth Featherstone v. Southern California Permanente Medical Group (“SCPMG”).  Featherstone, an at-will employee, took medical leave for surgery.  Seven days after returning to work, she called her supervisor to resign from her position.  The supervisor asked Featherstone to confirm her resignation in writing and immediately processed her exit and final paycheck.

Shortly thereafter, Featherstone was hospitalized for behavioral changes, though she still provided confirmation of her resignation in writing upon release.  A few days after that, Featherstone requested that SCPMG reverse her resignation, stating that she suffered adverse side effects from medication when she originally resigned from her position.  SCPMG considered Featherstone’s request, but ultimately decided not to reverse the resignation. Featherstone sued, alleging disability discrimination.

The appellate court agreed with the trial court’s determination in favor of SCPMG.  The company had not coerced Featherstone into resigning, had no knowledge of her ongoing medical status, and there was no employment contract in place between SCPMG and Featherstone.

Though arising from a distinct set of circumstances, this case demonstrates the benefits of maintaining clear documentation of workers’ employment status. 

 Action Items

1. Review separation procedures to ensure clear documentation and timely action.
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