Knight v. Johnson Controls: Medical Restrictions, the Interactive Process, and Damages

Knight v. Johnson Controls, Inc., No. A170587 (Cal. Ct. App. Oct. 9, 2026), affirmed a judgment and post-trial orders concerning failure to accommodate a disability and failure to engage in the interactive process. Its central factual distinction was between traveling to a job site and personally driving there. Its damages analysis addressed whether a voluntary resignation necessarily ended recovery when an employer’s FEHA violations caused later losses.

The opinion is unpublished. California Rules of Court, rule 8.1115 generally bars citation or reliance in other actions, subject to specified exceptions. This is a fact-specific case analysis, not a claim that Knight establishes citable California precedent or a general right to remote work.

The Return-to-Work Dispute and the Claims That Reached Trial

Knight was a project team leader overseeing HVAC installation projects. After medical leave, he sought to return with restrictions associated with treatment. Medical letters described treatment-day availability and a restriction on driving for 48 hours afterward. The employee’s account of his ability to communicate and work did not match every apparent implication of those letters. The employer characterized the request as an indefinitely part-time, partially remote arrangement incompatible with the position. Knight, slip op. at 2–6, 9, 13.

Knight responded that he and colleagues had discussed ways to continue the work. He asked HR to consult them before reaching a final conclusion. His May 2019 request for an update went unanswered; the next identified return-to-work letter arrived in January 2020 after litigation had begun. He resigned that month. The court’s analysis concerned that exchange and the trial evidence, not a rule that every lapse of a particular duration establishes liability. Knight, slip op. at 6–7, 17–19.

Before trial, the employer obtained summary adjudication of several claims, including disability discrimination and constructive discharge. Other claims were dismissed, leaving failure to accommodate and failure to engage in the interactive process for the jury. The absence of a surviving constructive-discharge claim became important to the employer’s damages argument. It did not eliminate those two separate FEHA causes of action. Knight, slip op. at 7–8.

The jury found that Knight could perform the essential duties with reasonable accommodation, that an effective accommodation had been available, and that the employer’s failures substantially caused harm. It awarded more than $1 million in economic damages, including $840,000 in future earnings, and $1.25 million in past plus $500,000 in future emotional-distress damages. It also awarded punitive damages, but the trial court granted JNOV and a new trial as to that award. The appellate result did not restore the punitive award. Knight, slip op. at 8, 29–30.

Substantial-Evidence Review and the FEHA Verdict

The court reviewed challenges to the jury’s factual findings under the substantial-evidence standard, drawing reasonable inferences and resolving conflicts in support of the judgment. It did not decide which witnesses it would have believed had it tried the case itself. The same distinction mattered to denial of JNOV; legal questions were reviewed independently, while denial of a new trial and its underlying determinations received the applicable standards. Knight, slip op. at 11–12, 20–21, 30.

That posture limits the lesson. Evidence supporting this jury’s verdict does not establish that every position involving site visits can accommodate a driving restriction. Nor does it require another factfinder to resolve materially different restrictions, duties, and communications the same way.

Travel Was Essential; Personally Driving Was Not Necessarily Essential

The employer argued that the medical letters prevented Knight from traveling and communicating with customers on three workdays and that no part-time position was available. The court evaluated the fundamental duties of the actual position, the means by which they had been performed, and the employee’s burden to show an available reasonable accommodation. It distinguished essential functions from marginal functions and recognized that an accommodation may alter when or how an essential function is performed. Knight, slip op. at 9–14.

Knight testified that he could work before and after a treatment window of approximately two to three hours, and his psychiatrist described variability in patients’ post-treatment ability to communicate. The opinion reports that testimony as evidence about this employee. It does not provide medical clearance for other patients or a reason to ignore their clinicians’ restrictions. Knight, slip op. at 13–14.

The job evidence also mattered. Knight had worked remotely 75–80 percent of the time, could schedule site travel, and had already used carpools, rideshare services, and public transportation. Colleagues had covered short absences before treatment, and evidence indicated that others handled some urgent on-site problems. The court held that a reasonable jury could find personal driving nonessential and certain brief coverage feasible. Knight, slip op. at 14–15.

The employer’s references to ad hoc visits did not compel a contrary conclusion. Some cited evidence did not specify the circumstances of required travel, and other testimony conflicted. The court remained bound by the verdict-supporting inferences permitted under substantial-evidence review. It did not remove travel from the position or announce that coverage can always replace essential work. Knight, slip op. at 15.

The Unclear Medical Notes Called for an Exchange, Not Assumptions

The employer argued that it was entitled to rely on the letters and that Knight failed to clarify his restrictions. The court recognized that both parties must participate in good faith and share relevant information; an employer is not liable where the employee is responsible for the breakdown. But the record supported the jury’s finding that the employer frustrated efforts to explain workable accommodations. Knight, slip op. at 15–19.

HR had requested more specific medical information, then interpreted the second letter as incompatible with the role without following up on Knight’s proposed arrangements. HR personnel acknowledged that the letter was nonspecific and did not align neatly with the first letter or the employee’s emails. The appellate court explained that a timely dialogue could have sought clarification from his doctors or identified precisely what information was needed. Knight, slip op. at 17–19.

This reasoning did not let an employee overrule a medical restriction. It concerned whether the parties could obtain accurate functional information and evaluate an available accommodation. A genuine absence of relevant information or a different allocation of responsibility for failed communication could produce a different result.

Voluntary Resignation Did Not Automatically Cut Off All Damages

The employer argued that because Knight voluntarily resigned and was not constructively discharged, he could not recover post-resignation economic losses. The court rejected a categorical cutoff for these FEHA claims. Following the damages reasoning it described from Cloud and related authority, it applied Civil Code section 3333’s causation-based compensation principle to failure to accommodate and failure to engage. The question remained whether the employer’s violation caused the claimed detriment. Knight, slip op. at 21–26.

The court did not equate resignation with an automatic entitlement to wages. It considered evidence that the failed process aggravated Knight’s condition, influenced his resignation, and affected his ability to obtain other work. The employer’s competing account did not permit the appellate court to substitute its weighing of the evidence for the jury’s. Knight, slip op. at 26–28.

Future losses also required a reasonable evidentiary basis. The court considered the employee’s established performance, age, compensation, commitment to the job, and the business’s longevity. The $840,000 future-earnings figure represented roughly eight years at the reported base annual salary, rather than an unsupported assumption of employment through retirement. The analysis upheld this award on this record; it did not guarantee a comparable award in another case. Knight, slip op. at 28–30.

Emotional Distress, Disposition, and Practical Limits

For noneconomic damages, the court considered employee and clinician testimony about aggravation of an existing condition and the resulting lasting impairment. It rejected the argument that lower awards in other cases compelled reversal: Each verdict depends on its evidence, and the record did not require the conclusion that passion or prejudice produced this award. This was appellate review of the evidence and trial court’s refusal to order a new trial, not an independent medical finding about every failed accommodation process. Knight, slip op. at 30–34.

The court affirmed the judgment and the orders denying the employer’s JNOV and new-trial challenges to the two FEHA claims and the economic and noneconomic awards. Knight, slip op. at 34. The opinion does not support advising an employee to resign, disregarding treatment restrictions, or assuming that transportation alternatives are always reasonable.

For the practical task of distinguishing driving from travel in an accommodation request, read our related Insight. The CRD accommodation guidance and rule 8.1115 provide the official agency and citation-rule context. Visit our employment practice for the firm’s services and contact options.