11-30-2016
Holly Hargett has suffered from epileptic seizures since childhood. Even with medication, she has remained at risk for suffering seizures. About eight years into her employment with Florida Atlantic University (“FAU”), Ms. Hargett alerted them to the fact that she was epileptic, that her seizures were often brought on by high “tension and stress,” and that she considered her work environment stressful.
Several years later, Ms. Hargett had a new supervisor. Ms. Hargett perceived her new supervisor as “rough” and “harsh.” He spoke angrily to her; he was unfriendly to her; he questioned her work; he refused to provide her training; and he micromanaged her work. This scrutiny was confirmed by witness testimony. Ms. Hargett’s physician advised FAU that it was “medically necessary” for her to step away from the stressful environment. She requested that the supervisor stop his “hostile confrontations” with her and that she be provided with “calm, fair, non-confrontational treatment.”
A federal district in Florida reviewed that request. It concluded that Ms. Hargett’s demand that her supervisor adopt a “less overbearing management style” was generally held to be “unreasonable.” An employee may be able to request that specific stressors be addressed, however, “an employee cannot immunize herself from stress and criticism in general.” Ms. Hargett did not provide specific stressors that were created by her supervisor. Thus, her accommodation requests were not reasonable and FAU was not required to act upon them.