In City of Moorpark v. Superior Court (1998) 18 Cal. 4th 1143, 959 P.2d 752, the high court considered whether the policy against disability discrimination in employment would support a common law wrongful discharge cause of action. Applying the Stevenson test, the court found the policy clearly delineated in FEHA, inuring to the public benefit and well established. ( Id. at pp. 1159-1160.) In considering whether the policy was "'substantial and fundamental,'" the court noted an employer may have valid reasons to treat a disabled employee differently than a nondisabled employee and FEHA recognized this fact by requiring only reasonable accommodation. ( Id. at p. 1160.) "But this caveat does not lead us to conclude that the policy against disability discrimination is not 'substantial and fundamental.' Even in the case of race, sex, and age discrimination, the FEHA does not prohibit discrimination that is 'based on bona fide occupational qualification.' ( Gov. Code, 12940.)