Bass v. County of Butte, 2006 WL 2348467 (9th Cir. 2006)

Allison Bass and two co-workers asserted employment discrimination claims against the County of Butte based upon the county’s alleged failure to accommodate their work-related disabilities. Plaintiffs alleged violation of the Unruh Civil Rights Act and the Disabled Persons Act on the theory that the two state statutes incorporated Title I (the anti-discrimination provision) of the Americans with Disabilities Act. (Although they could have, plaintiffs failed to assert claims under the California Fair Employment and Housing Act.) The Ninth Circuit affirmed summary judgment in favor of the county, concluding that neither state statute provided a cause of action for employment discrimination.