January 13, 2025 | JacobiJournal.com — A California federal court recently granted Costco Wholesale Corp. summary judgment, dismissing a claim of wrongful termination and Fair Employment and Housing Act (FEHA) violation filed by an injured worker. The court determined that Costco had met its obligation to accommodate the worker’s disability.
Background of the Case
Margarita Zamora, a long-time Costco employee, filed a lawsuit after a shoulder injury prevented her from lifting, pulling, or pushing more than 10 pounds. This injury made it impossible for her to return to her original job as a stocker.
Zamora suggested she could perform other tasks, like cleaning, if the company modified her role. However, the court ruled that FEHA does not require employers to create light-duty positions for workers unable to do essential job functions. Costco was not obligated to offer her a modified position with non-essential tasks, according to the court.
Court’s Ruling
Violation Claim Against Costco: The court found that Costco made reasonable efforts to accommodate Zamora. Despite trying to find alternative roles for her, the company could not offer a position that met her medical restrictions. In January 2021, Costco terminated her employment.
The court concluded, “Costco reasonably accommodated Zamora by offering vacant positions that aligned with her medical limitations.” The court emphasized that Costco had no duty to create a new position with tasks outside of Zamora’s restrictions.
Legal Precedents and Implications
This case reinforces that employers must engage in good-faith efforts to accommodate employees with disabilities. However, employers are not required to create modified roles or change essential job functions. They must demonstrate reasonable attempts to adjust existing roles to fit the employee’s medical needs.
For detailed coverage, read the original article from WorkCompCentral.
New Update: Costco FEHA Ruling Highlights Disability Accommodation Standards as Separate Case Advances in 2026
The federal court’s January 3, 2025 decision in Zamora v. Costco Wholesale Corporation remains an important example of how California’s Fair Employment and Housing Act (FEHA) applies when an injured employee cannot perform the essential functions of an existing position. U.S. District Judge Jon S. Tigar granted summary judgment in Costco’s favor after examining the company’s efforts to identify suitable vacant positions and accommodate Margarita Zamora’s permanent shoulder-related work restrictions. The court determined that Costco had engaged in an appropriate job assessment process, considered available alternatives, and provided medical leave beyond its standard policy.
The ruling also emphasized that reasonable accommodation requirements do not generally obligate an employer to create a new position or eliminate essential job duties. No subsequent appellate decision reversing the Zamora judgment was identified in the publicly available sources reviewed for this October 2026 update.
A separate California federal lawsuit involving Costco illustrates why FEHA accommodation disputes require individualized evaluation. In Ruch v. Costco Wholesale Corporation, a federal court considered claims involving an employee with medical restrictions who sought accommodations in her front-end cashier position. In a 2026 ruling, the court denied significant portions of Costco’s motion for summary judgment after finding genuine factual disputes concerning whether the employee could perform essential job functions with reasonable accommodations and whether the company adequately participated in the interactive process.
The court examined evidence about specific checkout assignments, possible modifications, and Costco’s handling of the employee’s accommodation requests. Unlike the Zamora decision, the Ruch litigation involved disputed evidence that prevented the court from resolving several claims in the employer’s favor without further proceedings.
These decisions demonstrate that California disability accommodation law does not produce identical outcomes for every injured worker or employer. Under FEHA, employers must evaluate reasonable accommodations, consider reassignment to appropriate vacant positions when necessary, and participate in a timely, good-faith interactive process. However, the law generally does not require creating an entirely new job or permanently removing essential duties from an existing position.
The distinction between the two Costco cases lies in their particular evidence, including the employee’s restrictions, the nature of available work, the accommodations considered, and whether material facts remained disputed. The 2026 Ruch ruling does not overturn or modify the Zamora judgment, and denial of summary judgment does not establish that Costco ultimately violated FEHA in the separate case.
FAQs: Costco FEHA Termination Case
What was the Costco FEHA termination case about?
The case involved a Costco employee who claimed the company failed to accommodate her shoulder injury, leading to her termination.
How did the court rule in the Costco FEHA termination case?
The court dismissed the claim, finding Costco had reasonably accommodated the worker by offering alternative positions within her restrictions.
Does FEHA require employers to create new roles for injured employees?
No, the court clarified that FEHA requires reasonable accommodation but does not obligate employers to create modified or light-duty positions.
What does the termination case mean for employers?
It reinforces that employers must show good-faith efforts to accommodate workers but are not required to alter essential job functions or invent new roles.
What is FEHA and who does it protect?
FEHA, the California Fair Employment and Housing Act, protects employees from discrimination based on disability, race, gender, and other protected categories. It requires employers to provide reasonable accommodations for qualified employees with disabilities.
What counts as reasonable accommodation under FEHA?
Reasonable accommodation can include modifying work schedules, providing assistive equipment, or reassigning an employee to an existing vacant position that fits their restrictions. Employers are not required to create new roles or remove essential job duties.
Can an employee be terminated if they cannot perform essential job functions?
Yes. Under FEHA, an employer can terminate an employee if no reasonable accommodations are available that allow the employee to perform the essential functions of their position.
Does this Costco case set a precedent for other employers?
The case reinforces that employers must engage in good-faith accommodation efforts but are not obligated to invent new roles or modify essential job duties. It provides guidance on balancing accommodation duties with operational needs.
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