Shirvanyan v. Los Angeles Community Coll. Dist., 2020 WL 7706321 (Cal. Ct. App. 2020)

Anahit Shirvanyan, a former kitchen assistant employed by the District, alleged the District failed to reasonably accommodate and/or engage in the interactive process with her based upon two injuries she had suffered (a wrist injury from carpal tunnel syndrome and a shoulder injury). Because the jury did not indicate whether it had relied upon one or both of the alleged injuries in awarding Shirvanyan a verdict of $2.9 million (including $2.8 million in emotional distress damages), the Court of Appeal reversed the judgment and remanded the case for a new trial on her claims for failure to accommodate/engage in the interactive process vis-à-vis the wrist injury. While a reasonable accommodation (a finite period of leave) was available for the wrist injury, there was no substantial evidence that an accommodation was available for the shoulder injury because Shirvanyan could not have engaged in many of the essential job duties as a kitchen assistant with the shoulder injury, and there were no other vacant positions for which she was qualified at the time.