Disabled employees are entitled only to reasonable accommodations.
CASE ON POINT: Ceazan v. Saint John's Hospital & Health Center, 2004 WL 788201-CAISSUE: By law, employers are required to provide "reasonable accommodations" for employees who have disabilities. However, in this extraordinary California case, a hospital was confronted with a "no win" situation. The hospital apparently valued an employee and made several attempts to accommodate her. However, no accommodation was satisfactory. Employees can not demand "unreasonable" accommodations.
CASE FACTS: Barbara Ceazan, a registered nurse, was hired by Saint John's Hospital and Health Center in January of 1990. During her employment, Nurse Ceazan acknowledged the receipt of the Hospital's Employee Handbook, which specified that the employer/employee relationship is an at-will relationship, subject to termination at any time, without advance notice. Nurse Ceazan was promoted to the position of "team leader" of the Ambulatory Medicine Unit. Later, she began to oversee the Emergency Department (ED). As team leader, Nurse Ceazan was in charge of the nursing staff and the nonclinical employees in her unit. She supervised some 78 employees. She and 10 other hospital team leaders reported directly to Paula Smith, the hospital's vice-president of patient care services. By state law and internal hospital policy, Smith was responsible for all of the hospital's clinical nursing staff. Nurse Ceazan found Smith to be "harsh, belligerent, and autocratic." In 1999, Nurse Ceazan experienced various incidents of condescension, general hostility, and mistreatment by Smith. In May of 1999, Nurse Ceazan resigned as ED team leader due to Smith's unsupportive attitude. Smith agreed that Nurse Ceazan's salary would not be lowered despite her diminished responsibilities; however, while Nurse Ceazan's salary remained unchanged, her pay grade status was reduced. In October of 1999, Nurse Ceazan filed a grievance claiming that she was "wrongfully demoted and was maltreated by Smith." The grievance committee concluded that a "suboptimal working relationship" existed between the two; though, there was no evidence of harassment or a hostile work environment. The Committee identified behavioral problems in both, and recommended that their working relationship be improved with the help of a facilitator. The grievance committee also recommended that Nurse Ceazan be "restored to a higher pay grade." Nurse Smith appealed the decision of the grievance committee. The appeal was heard by a hospital vice-president, who overturned the grievance committee's decision. After learning of this, Nurse Ceazan became increasingly depressed and unable to work. She took a medical leave from the hospital on the grounds of temporary total mental disability and applied for workers' compensation benefits. Nurse Ceazan underwent counseling and was prescribed antidepressants. A psychiatrist believed that her disability was caused by her employment. In September 2000, Nurse Ceazan's psychiatrist authorized her to return to work at the hospital but recommended that she not be directly supervised by Smith. Nurse Ceazan maintained that the hospital should have made a reasonable accommodation for her by "allowing [her] to return to a place of employment that [she] wanted to" that did not require her to report to Smith. Nurse Ceazan did not respond to an offer extended by the hospital that she be given a clinical nursing position and nonmanagerial job that would not require her to report to Smith. She claimed that she was constructively discharged due to the hospital's failure to accommodate her disability. Nurse Ceazan filed a discrimination claim with the Department of Fair Employment and Housing. She filed suit against the hospital for wrongful termination and breach of contract. The trial court granted the hospital's motion for summary judgment. Nurse Ceazan appealed.
COURT'S OPINION: The Court of Appeal of California affirmed the judgment of the lower court. The court held, inter alia, that the FEHA prohibits employers from discriminating against employees with physical and mental disabilities. However, employees can not demand unreasonable accommodations.
LEGAL COMMENTARY: An employer is not obligated to choose the "best" accommodational an employee seeks. Rather, "the employer providing the accommodation has the ultimate discretion to choose between effective accommodations, and may choose the less expensive accommodation or the accommodation that is easier for it to provide." An employee cannot make his employer provide a specific accommodation if another reasonable accommodation is provided instead.
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| Title Annotation: | Hospital Law Case of the Month |
|---|---|
| Author: | Tammelleo, A. David |
| Publication: | Hospital Law's Regan Report |
| Geographic Code: | 1USA |
| Date: | Apr 1, 2004 |
| Words: | 686 |
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