Gibbs

An airline worker claimed her employer unlawfully denied her statutory medical leave, despite having notice of her serious health condition, and intentionally inflicted emotional distress. (Gov. Code, § 12945.2, subds. (a), (c)(3)(C).) The jury returned a split verdict, finding in favor of the employer on the medical leave claim but in favor of the worker on the emotional distress claim. The jury found that the worker had not given her employer notice of her need for medical leave. The employer and worker separately moved for judgment notwithstanding the verdict (JNOV) or to vacate the judgment. (Code Civ. Proc., § 629.) The trial court denied the worker’s motion but granted the employer’s motion upon concluding that workers’ compensation was the exclusive remedy for work-related emotional distress. (Lab. Code, § 3601, subd. (a).) We affirm the trial court’s rulings and the judgment.

I. Facts

Appellant Gibbs worked at respondent American Airlines, Inc. (American Airlines) from 1989 to 1995. Gibbs was a service representative in the Admiral’s Club at the San Francisco airport in her last few years at American Airlines. Gibbs assisted club members with travel arrangements…