Washington Court Upholds Dismissal of Fire Department Mechanic’s Disability Lawsuit

The Washington Court of Appeals has affirmed the dismissal of a disability discrimination lawsuit brought by a fire department mechanic against the City of Tacoma. The case centered on whether the City failed to accommodate Liam Riley’s medical conditions under the Washington Law Against Discrimination (WLAD). Riley alleged that workplace conflicts triggered serious hypertension episodes and that the City failed to reasonably accommodate his request for a transfer.

Riley, who began working for the City in 2013, served as a mechanic in the fire department’s garage. He claimed that ongoing conflicts with coworkers—ranging from verbal disputes to alleged threats—exacerbated his hypertension and anxiety, leading to multiple hospitalizations. Quoting from the decision:

• Starting in 2013, Riley suffered from numerous health problems, including marked obesity, chronic fatigue, mood swings, irritability, and joint pain.
• Riley also had high blood pressure for many years before he started working for the City.
• In 2018, Riley began to report conflict with his coworkers.
• Generally, he complained that they did not provide him with parts and supplies in a timely way, and coworkers were rude and disrespectful to him.
• Riley testified that his coworkers called him the boss’s “pet and his golden boy” and said “that [Riley]would get away with everything.”
• Riley also testified that one of his coworkers Carol Haeger once raised her hand at him as if she was going to slap him but did not.
• Riley said another coworker told Riley on multiple occasions he was going to “kick [his] ass.”
• On June 13, 2018, Riley argued with Haeger over auto parts, and he reported that Haeger screamed at him.
• Riley said that Haeger had purposefully violated garage protocol and placed boxes behind the vehicle he was working on and he ran them over.
• Fire department personnel checked his blood pressure and reported to him that it was 228 over 140.
• An ambulance took Riley to the hospital where he had a similarly high blood pressure reading. Riley complained that while he was on the gurney, Haeger looked at him with “hate and disdain.”

In 2019, Riley requested to be reassigned to a “safe and healthy work environment” as an accommodation. The City initiated the interactive process and provided medical questionnaires for Riley’s healthcare providers to complete.

While Riley submitted initial documentation from his physician and therapist, the city found those forms insufficient. The records failed to establish which essential functions of Riley’s job he could not perform due to his condition. Moreover, they did not support the claim that a workplace transfer was medically necessary. After initially participating, Riley withdrew from the process, later sought to resume it, and repeatedly declined to submit updated documentation despite multiple written requests from the City.

The Court of Appeals emphasized that under WLAD, both the employer and employee have a duty to cooperate in the interactive accommodation process. The Court concluded that Riley did not meet his obligation to provide sufficient medical information linking his conditions to the functions of his job. Notably, an independent medical examiner later found Riley fully capable of performing his duties without accommodation.

The court also upheld the dismissal of Riley’s hostile work environment claim, finding that his complaints—while personally distressing—amounted to isolated incidents and were not tied to his disability. In other words, there was insufficient evidence that his coworkers’ conduct was so severe as to alter the conditions of his employment, nor that his coworkers engaged in the unwelcome harassment because of his disability.

In rejecting Riley’s claims, the court reiterated that interpersonal conflict alone, even if stressful, does not qualify as a disability requiring accommodation under the law.

Here is a copy of the decision: