Husband v. Target Corporation: California Court Clarifies When an Employer Is Deemed to Know About an Employee’s Disability
Employers cannot accommodate disabilities they do not know exist. Yet workplace disputes often arise when an employee experiences symptoms of a medical condition without formally disclosing a diagnosis. A recent California Court of Appeal decision examined where the line should be drawn between what an employer actually knows and what it can reasonably be expected to infer.
In Husband v. Target Corporation (2026) ___ Cal.App.5th ___, the California Court of Appeal affirmed summary judgment in favor of Target, holding that evidence of unusual behavior, emotional outbursts, and concerns about an employee’s well-being did not establish that the employer knew or should have known the employee suffered from bipolar disorder. The decision provides important guidance for employers and employees navigating disability discrimination and accommodation issues under California law.
A Long-Time Employee Experiences Mental Health Challenges
The plaintiff worked for Target for many years and eventually became an executive team leader. During his employment, he was diagnosed with bipolar I disorder. Despite the diagnosis, he never informed Target that he suffered from bipolar disorder and never requested a workplace accommodation related to the condition.
Over time, coworkers and supervisors observed conduct they considered unusual. The employee sometimes displayed emotional volatility, made irrational statements, became agitated during workplace interactions, and caused others to worry about his mental and emotional state. At various points, supervisors expressed concern for his well-being and encouraged him to seek assistance through Target’s employee assistance resources.
The employee eventually experienced a severe mental health crisis that led to hospitalization and treatment. Following subsequent employment actions, he filed suit against Target.
The Lawsuit
The employee asserted multiple claims under California’s Fair Employment and Housing Act (FEHA), including disability discrimination, failure to provide a reasonable accommodation, and failure to engage in the interactive process.
His central argument was that although he never disclosed his bipolar disorder diagnosis, Target should have recognized from his conduct that he suffered from a mental disability. According to the employee, the company’s observations of his behavior were sufficient to place it on notice of his condition and trigger FEHA obligations.
Target moved for summary judgment, arguing it had no actual knowledge of the bipolar disorder and that the observed behavior could not reasonably establish constructive knowledge of the diagnosis.
The trial court agreed and entered judgment for Target. The employee appealed.
The Court Examines Employer Knowledge Under FEHA
The appeal focused on a critical issue that frequently arises in disability cases: when can an employer be charged with knowledge of a disability it was never told about?
The Court of Appeal emphasized that FEHA generally requires an employer to know about a disability before liability can arise for disability discrimination, failure to accommodate, or failure to engage in the interactive process.
The court explained that an employer is not expected to act as a medical diagnostician. Workplace supervisors may observe behavior that is unusual, disruptive, emotional, or concerning for many reasons unrelated to a legally protected disability.
As a result, the court rejected the argument that evidence of unusual conduct automatically creates a triable issue regarding employer knowledge of a disability.
Different Standards Apply to Different FEHA Claims
One of the most significant aspects of the opinion is its clarification that different FEHA claims require slightly different analyses of employer knowledge.
For disability discrimination claims, the court held that knowledge may be inferred only when disability is the only reasonable interpretation of the facts known to the employer.
In other words, if the employee’s conduct could reasonably be explained by a variety of causes, an employer cannot automatically be charged with knowledge of a disability.
For failure-to-accommodate and failure-to-engage-in-the-interactive-process claims, the court articulated an even narrower rule. Knowledge may be inferred only when the disability is obvious or when the observed symptoms are so clearly manifestations of a disability that the existence of a disability necessarily follows from them.
The court emphasized that FEHA does not require employers to speculate about possible medical conditions based on ambiguous workplace behavior.
Why the Employee’s Evidence Was Not Enough
Applying those principles, the Court of Appeal concluded that Target was entitled to judgment as a matter of law.
Although supervisors observed troubling conduct and expressed concern about the employee’s well-being, those observations did not compel the conclusion that he suffered from bipolar disorder or any other specific disability.
The court noted that emotional outbursts, irrational comments, agitation, workplace conflicts, and personal difficulties can arise from numerous causes. They do not necessarily indicate the existence of a disability, much less a particular psychiatric diagnosis.
Because the employee never disclosed his condition, never provided medical documentation, and never requested accommodation, the evidence failed to establish that Target knew or reasonably should have known he had bipolar disorder.
Without the required knowledge element, the employee’s FEHA claims could not proceed.
The Court of Appeal therefore affirmed the judgment in favor of Target.
Practical Lessons for Employers and Employees
The decision highlights a recurring challenge in workplace disability law. Employers have substantial obligations once they know about a disability or become aware of circumstances that clearly indicate one exists. At the same time, FEHA does not require employers to diagnose employees or infer medical conditions from ambiguous behavior.
For employers, the case reinforces the importance of responding appropriately when employees disclose medical conditions or request accommodations. It also confirms that concern for an employee’s well-being does not automatically translate into legal knowledge of a disability.
For employees, the decision serves as a reminder that requesting an accommodation generally requires some communication that a medical condition is affecting the ability to perform job duties or requires workplace adjustments. An employer’s mere observation of unusual behavior may not be enough to trigger FEHA obligations.
The court’s opinion provides valuable guidance on the limits of constructive notice and offers a clearer framework for evaluating disability-related claims where the employee never expressly disclosed a medical condition.
Husband v. Target Corporation was decided by the California Court of Appeal, Second Appellate District, Division Five, on May 21, 2026, Case No. B342334. The Court of Appeal affirmed summary judgment in favor of Target Corporation, holding that the employee failed to present evidence that Target knew or reasonably should have known he suffered from bipolar disorder. As a result, his disability discrimination, failure-to-accommodate, and failure-to-engage-in-the-interactive-process claims under FEHA could not proceed.