Weyer v. Twentieth Century Fox Film Corp.
2000 WL 1643, 198 F.3d 1104 (2000)
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Rule of Law:
Title I of the Americans with Disabilities Act (ADA) does not permit claims from former employees who are totally disabled and unable to perform the essential functions of a job. Furthermore, Title III of the ADA prohibits discrimination related to physical access to public accommodations but does not regulate the content of insurance policies offered as an employment benefit.
Facts:
- Helen Weyer worked for Twentieth Century Fox Film Corporation ('Fox').
- As an employment benefit, Fox offered its employees a group long-term disability insurance policy administered by UNUM Life Insurance Company of America ('UNUM'), which Weyer purchased.
- The policy limited benefits for disabilities resulting from mental illness to a maximum of 24 months.
- In contrast, benefits for physical disabilities under the same policy could continue until age 65.
- In March 1994, Weyer became unable to work due to severe depression, rendering her totally disabled.
- Weyer received disability benefits from UNUM for two years.
- In March 1996, UNUM terminated Weyer's benefits based on the 24-month limitation for mental disabilities.
Procedural Posture:
- Helen Weyer filed a lawsuit against her former employer, Twentieth Century Fox Film Corporation ('Fox'), and its insurance administrator, UNUM Life Insurance Company of America ('UNUM'), in a federal district court.
- The lawsuit alleged that the defendants' disability insurance plan violated Titles I and III of the Americans with Disabilities Act, as well as related Washington state statutes.
- The district court granted summary judgment in favor of Fox and UNUM on all counts.
- Weyer, as the appellant, appealed the district court's grant of summary judgment to the United States Court of Appeals for the Ninth Circuit.
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Issue:
Does a long-term disability insurance policy that provides fewer benefits for mental disabilities than for physical disabilities violate Title I or Title III of the Americans with Disabilities Act when challenged by a totally disabled former employee?
Opinions:
Majority - Kleinfeld, Circuit Judge
No, the policy does not violate Title I or Title III of the ADA. To bring a claim under Title I, an individual must be a 'qualified individual with a disability,' defined as someone who 'can perform the essential functions of the employment position.' Because Weyer is totally disabled and cannot perform her job functions, she is not a 'qualified individual' and lacks standing to sue under Title I. The statute's use of present-tense language ('can perform,' 'holds or desires') limits its protection to current employees and job applicants, not former employees unable to work. Furthermore, Title III prohibits discrimination in the enjoyment of 'public accommodations,' which the court interprets as physical places. Weyer's claim concerns the content of an insurance policy, not her physical access to an insurance office. Title III governs access to goods and services, not their substantive content. Finally, the ADA's 'safe harbor' provision permits insurers to classify risks, and distinguishing between mental and physical disabilities is a standard underwriting practice, not a subterfuge to evade the Act.
Analysis:
This decision reinforces the majority circuit view that Title I of the ADA does not protect totally disabled former employees challenging the terms of post-employment fringe benefits. It creates a significant barrier for plaintiffs by establishing a 'catch-22': an employee is not yet harmed by a discriminatory benefit plan while able to work, but loses standing to sue under Title I once they become totally disabled and can no longer work. The ruling also narrowly construes Title III, limiting its reach to physical access and leaving the substantive content of insurance policies largely unregulated by the ADA's public accommodations provisions. This interpretation places the onus on Congress, rather than the courts, to mandate parity between mental and physical disability benefits.
