Husband v. Target Corp., 2026 WL 1430244 (Cal. Ct. App. 2026)

Daniel Husband worked as a fulfillment expert for Target Corp. Husband’s employment was terminated for violations of Target’s workplace violence policy following a series of “threats of violence against coworkers.” Husband sued Target for disability discrimination and related claims. During his deposition, Husband admitted he never informed Target that he had been diagnosed with bipolar I disorder. However, in an (attorney‑prepared) declaration filed in opposition to Target’s summary judgment motion, Husband claimed he had “mentioned” his diagnosis to human resources during orientation. Consistent with long‑standing precedent, the court disregarded the declaration because it contradicted Husband’s prior deposition testimony. The trial court granted Target’s summary judgment motion because Target had no knowledge of Husband’s alleged mental disability and because Husband never sought an accommodation from Target. The Court of Appeal affirmed summary judgment in favor of Target, holding that an employer will not be charged with knowing an employee has a disability unless the facts known to the employer make the existence of a disability “the only reasonable interpretation” of those facts.