Fletcher v. Tufts University
367 F.Supp.2d 99, 34 Employee Benefits Cas. (BNA) 2409, 16 Am. Disabilities Cas. (BNA) 1228 (2005)
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Rule of Law:
Under Title I of the Americans with Disabilities Act (ADA), totally disabled former employees are 'qualified individuals' with standing to sue for discrimination in post-employment fringe benefits. An employer-sponsored disability plan that provides fewer benefits for mental disabilities than for physical disabilities constitutes prima facie discrimination, and the applicability of the ADA's 'safe harbor' provision for insurance risk classification is an affirmative defense that the defendant must prove.
Facts:
- Madeleine Fletcher was a professor of Spanish literature at Tufts University, beginning in 1980.
- As part of her employment, Fletcher subscribed to a long-term disability (LTD) plan offered by Tufts and issued by Metropolitan Life Insurance Company (MetLife).
- The LTD Plan provided benefits until age 65 for physical disabilities but limited benefits to 24 months for mental disabilities, unless the beneficiary was confined to a hospital.
- In April 1998, Fletcher was hospitalized and diagnosed with bipolar disorder, a mental illness.
- Following a medical leave, Fletcher was deemed unable to work, and on February 28, 1999, she began receiving LTD benefits from MetLife.
- On February 27, 2001, after two years, MetLife terminated Fletcher's benefits pursuant to the plan's 24-month limitation for non-hospitalized mental disabilities.
- In August 2001, a physician conducted a 'return to work evaluation' and concluded Fletcher was incapable of performing her job's essential functions, after which Tufts informed her she could not return to her position.
Procedural Posture:
- On December 10, 2001, Fletcher filed charges of discrimination against Tufts and MetLife with the Equal Employment Opportunity Commission (EEOC).
- The EEOC issued 'right to sue' notices to Fletcher on February 20, 2002.
- On May 20, 2002, Fletcher filed suit against Tufts and MetLife in the U.S. District Court for the District of Massachusetts, the court of first instance.
- The complaint alleged a violation of Title I of the ADA by Tufts and a violation of Title III of the ADA by MetLife.
- Fletcher later amended her complaint to add a claim under the Employee Retirement Income Security Act (ERISA) against both defendants.
- Both Tufts and MetLife filed motions to dismiss all claims pursuant to Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim upon which relief can be granted.
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Issue:
Does an employer-sponsored long-term disability plan that provides a shorter duration of benefits for mental disabilities than for physical disabilities violate Title I of the Americans with Disabilities Act?
Opinions:
Majority - Lindsay, District Judge
Yes, an employer-sponsored long-term disability plan that provides a shorter duration of benefits for mental disabilities than for physical disabilities states a claim for a violation of Title I of the ADA. First, a former employee who is totally disabled has standing to sue as a 'qualified individual' for discrimination in post-employment fringe benefits. To hold otherwise would nullify the ADA's protections for such benefits, which are only claimed when an individual can no longer work. Second, applying the Supreme Court's broad interpretation of discrimination from Olmstead v. L.C., the ADA prohibits discrimination not only between the disabled and non-disabled but also among members of the protected class. Distinguishing between types of disabilities is therefore prima facie discrimination. Finally, the ADA's 'safe harbor' provision, which permits risk classification in insurance, is an affirmative defense. The defendant, not the plaintiff, bears the burden of pleading and proving that the distinction is based on sound actuarial principles or reasonably anticipated experience.
Analysis:
This decision represents a significant departure from the majority of federal circuits at the time, which had held that providing different benefits for mental and physical disabilities was not discriminatory so long as the plan was offered equally to all employees. By applying the Supreme Court's reasoning from Olmstead (a Title II case) to the Title I employment context, the court broadened the concept of disability discrimination to include disparate treatment among different types of disabilities. Crucially, by classifying the ADA's insurance 'safe harbor' as an affirmative defense, the court shifted the burden of proof to employers and insurers to justify such distinctions with actuarial data, making it substantially easier for plaintiffs to survive a motion to dismiss.
