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Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

contractplaintiffdamagesappealtrialburden of proofdiscriminationlegislative intentjury instructions
contractplaintiffstatuteappealdiscriminationstatutory interpretation

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Green v. State of California, 42 Cal.4th 254, 165 P.3d 118, 64 Cal.Rptr.3d 390, 19 A.D. Cases 1092, 07 Cal. Daily Op. Serv. 9951, 2007 Daily Journal D.A.R. 12,799

Facts

The plaintiff began working for the State of California in 1974 and was diagnosed with Hepatitis C in 1990, presumably contracted from sewer pipes at the facility. He continued to work without restrictions until 1997 when he began treatment that caused fatigue and other side effects. After a back injury in 1999, he was placed on light duty and subsequently on disability leave. Despite being cleared for full duty in 2000, he was denied return to work based on a prior medical report. The plaintiff filed a disability discrimination claim, and the jury awarded him damages, which the trial court later reduced.

In 1990, plaintiff was diagnosed with hepatitis C. Plaintiff presumably contracted the disease while working on the sewer pipes at the Institute. From 1990 until 1997, plaintiff did not have any work restrictions because of the illness, nor did he lose any time from work.

Issue

The main legal issue was whether the burden of proof regarding the plaintiff's ability to perform the essential duties of his job under the FEHA lies with the plaintiff or the employer.

The issue in this case is simple: In an action for disability discrimination under California's Fair Employment and Housing Act (FEHA) ( Gov.Code, § 12900 et seq. ), which party bears the burden of proving that the plaintiff's disability did or did not prevent the plaintiff from performing the essential duties of the job?

Rule

Under the FEHA, a plaintiff must demonstrate that he or she is a qualified individual who can perform the essential duties of the job with or without reasonable accommodation, similar to the requirements under the Americans with Disabilities Act (ADA).

The FEHA prohibits discrimination against any person with a disability but, like the ADA, provides that the law allows the employer to discharge an employee with a physical disability when that employee is unable to perform the essential duties of the job even with reasonable accommodation.

Analysis

The court analyzed the statutory language and legislative intent of the FEHA, concluding that it requires plaintiffs to prove their ability to perform essential job functions. The court found that the failure to instruct the jury on this burden constituted reversible error, as it misrepresented the legal standards applicable to the case.

We therefore begin our statutory analysis with a comparison of the ADA and the FEHA provisions at issue. We then discuss plaintiff's statutory interpretation and why we disagree with it under the premise that a statute's meaning is guided by the plain words the Legislature chose.

Conclusion

The Supreme Court reversed the judgment of the Court of Appeal and remanded the case for further proceedings, emphasizing the necessity of proper jury instructions regarding the burden of proof.

We therefore reverse the judgment of the Court of Appeal and remand the matter for proceedings consistent with this decision.

Who won?

The State of California prevailed in the Supreme Court's decision, as the court ruled that the plaintiff had the burden of proof regarding his ability to perform essential job duties.

We therefore reverse the judgment of the Court of Appeal and remand the matter for proceedings consistent with this decision.

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