LISA FOWLER vs. AUTOMOBILE CLUB OF SOUTHERN CALIFORNIA, LIBERTY MUTUAL
The Workers' Compensation Appeals Board granted reconsideration and reversed a prior finding that Automobile Club of Southern California discriminated against Lisa Fowler under Labor Code section 132a. The Board found Fowler failed to establish a prima facie case of discrimination because her termination resulted from her failure to return to work after being released by her physician, in accordance with a uniformly applied company attendance policy. The employer's witness testified that work-related and non-work-related leaves were treated the same. Therefore, Fowler was not singled out for disadvantageous treatment compared to similarly situated employees.