Bass

Plaintiffs Allison Bass, Thomas Parks, and John Muldown asserted employment discrimination claims against Defendant County of Butte and others based on Defendant’s alleged failure to accommodate their work-related injuries. All three Plaintiffs raised their employment claims under California’s Unruh Civil Rights Act (“Unruh Act”), Cal. Civ.Code § 51, and Disabled Persons Act (“DPA”), Cal. Civ. Code §§ 54 , 54.1, on the theory that the two state laws incorporate Title I of the Americans with Disabilities Act of 1990 (“ADA”), 42 U.S.C. §§ 12101-12213 . We disagree.

This case consolidates the separate actions of three Plaintiffs against the County of Butte. Each of the three Plaintiffs suffered an on-the-job injury and sought accommodation from the County for his or her resulting physical impairment. Plaintiffs claim that the County failed to offer them reasonable accommodations.

In 2002, Plaintiffs filed separate complaints, each seeking monetary damages and declaratory relief against Butte County, Butte County Sheriff Scott Mackenzie, and Lieutenant William Anderson. Plaintiffs raised both federal and state causes of action including claims under the Rehabilitation Act of 1973,…