Overview
- The California Court of Appeal on May 21, 2026 affirmed summary judgment for Target in Husband v. Target and held that an employer is charged with knowledge of an employee’s mental disability only when the disability is the only reasonable interpretation of the facts.
- The court reviewed episodes of alarming conduct by employee Daniel Husband, who never told Target he had bipolar disorder, and found the record supported other plausible causes such as drugs, prescription interactions, or sleep loss.
- Judges rejected imputing knowledge based on a supervisor’s subjective view that the employee “needed help” or should go to a hospital and warned that treating any unusual or bizarre act as notice would let every odd incident go to a jury.
- The decision clarifies that employers may suggest treatment, excuse an employee, or invoke safety policies without automatically triggering FEHA accommodation duties, but those actions should be documented and routed to HR or counsel.
- Practical impact: employers should train supervisors to avoid diagnostic speculation, promptly record exact behaviors and statements, and seek HR or legal advice when behavior risks safety or may point to a medical condition that could be proven by disclosure or medical evidence.