In March 2016, plaintiff Elizabeth Carter, a customer-service lead, was terminated by her employer, Dunn-Edwards Corp. Carter was hired to work at Dunn-Edwards’ North Hollywood paint store on June 22, 2015. According to the company’s job posting, the position was “responsible for providing superior customer service at the point of sale,” and other tasks, including lifting items weighing up to 72 pounds. However, Carter had a back injury that limited her ability to lift objects weighing more than 20 pounds. She claimed that she required reasonable accommodation to perform the job and that when she needed help with lifting anything, she requested assistance from her co-workers, who always helped her. On Nov. 20, 2015, Dunn-Edwards allegedly informed Carter that she had exhausted the company’s 90-day modified-duty policy and requested that Carter either get a medical release that permitted her to lift up to 65 pounds at work or go on a leave of absence. Carter went on medical leave, which was extended until March 2016. At the end of her medical leave extension, Cater still had the same medical restrictions regarding lifting more than 20 pounds and squatting. Dunn-Edwards terminated Carter’s employment in March 2016. Carter sued Dunn-Edwards Corp., alleging that the company’s actions constituted disability discrimination, failure to accommodate, failure to engage in the interactive process, and failure to prevent discrimination and harassment in violation of the Fair Employment and Housing Act. She also alleged that Dunn-Edwards’ actions constituted a wrongful discharge in violation of public policy and retaliation for requesting a disability accommodation. Following defense counsel’s motion, the court ordered the matter to arbitration. Carter claimed that she performed her job without any incidents and that she even received a positive performance evaluation, but that she was forced to go on medical leave and eventually fired as a result of her disability. Carter’s counsel contended that Dunn-Edwards had an illegal 90-day accommodation policy, in which the company would accommodate employee disabilities for only 90 days and no more without doing the requisite individual assessment to determine whether further accommodation was reasonable. Counsel contended that, thereafter, the company would place disabled employees on medical leave, even if one was not required, until the employee was ready to return to full duty. Plaintiff’s counsel asserted that the leave policy was illegal because it arbitrarily limited the length of the leave without regard to the individual’s needs. Defense counsel noted that although Carter claimed she had a back injury that limited her ability to lift more than 20 pounds, her written application did not specify a disability. Counsel also noted that although Carter claimed she required “reasonable accommodations to perform the job,” when Carter started her employment, she noted in a company form that she was not disabled and needed no accommodation. Regardless, Dunn-Edwards’ counsel asserted that Carter was unable to perform the essential functions of her job due to Carter’s inability to lift more than 20 pounds or squat and that no reasonable accommodation was available other than a leave of absence. Counsel also asserted that the only potential accommodation of assigning other employees Carter’s duties that required lifting and/or squatting, which was urged by Carter, was not reasonable as a matter of California law., Carter claimed that she suffered a loss of earnings as a result of her termination. She also noted that she was not paid during her medical leave. Carter was able to secure a new job shortly after her termination. Carter claimed that she suffered emotional distress as a result of the events at Dunn-Edwards. A therapist diagnosed Carter with “generalized anxiety disorder” and “adjustment disorder with mixed anxiety and depressed mood.” Carter underwent six sessions with that therapist. Carter sought recovery of $10,880 for her past loss of earnings. She also sought recovery of noneconomic damages for her emotional pain and suffering, and recovery of punitive damages. In addition, Carter sought injunctive relief and declaratory relief to invalidate Dunn-Edwards’ 90-day policy.