Managers are often difficult or contentious, which understandably causes employees stress. But stress caused only by a difficult boss does not qualify as a "disability" under California law.
In Higgins-Williams v. Sutter Medical Foundation, the plaintiff took medical leave because of difficulties with her immediate supervisor and the Human Resources manager. The plaintiff did not suffer from any other conditions, besides stress caused by dealing with her supervisors. After her medical leave expired, the employer, Sutter, asked the plaintiff to return to work. She then requested an accommodation for her stress, preferably a transfer away from her problem supervisors. But the court ruled that an employee's "inability to work under a particular supervisor because of anxiety and stress related to the supervisor's standard oversight of the employee's job performance does not constitute a disability..." While the ruling may leave wiggle room for situations where supervisors unfairly target employees, those will be the exceptions. Going forward, employees should assume that they cannot request disability accommodations simply because they do not get along with their bosses.