## Facts

- Madeleine Fletcher was a tenured professor at Tufts University and participated in Tufts’s employer-sponsored long-term disability (LTD) plan issued and administered by Metropolitan Life Insurance Company (MetLife).
- In 1998, Tufts raised concerns about Fletcher’s mental health after a letter she sent to a class; she was hospitalized and diagnosed with bipolar disorder with psychotic features, and later treated for an ongoing psychotic disorder.
- Tufts placed Fletcher on medical leave (Sept. 1, 1998–Jan. 31, 1999). MetLife approved her LTD claim, and she received benefits from Feb. 28, 1999 to Feb. 27, 2001.
- The plan limited benefits to 24 months for a participant “disabled due to mental illness and not confined” in a hospital or institution; by contrast, benefits for physical disabilities could continue to age 65.
- MetLife terminated Fletcher’s benefits after 24 months based on the plan’s mental-illness limitation and the absence of institutional confinement.
- In 2001, a return-to-work evaluation concluded Fletcher could not perform essential job functions and no accommodation would enable her to work; Tufts then terminated her employment.
- Fletcher sued Tufts and MetLife asserting: (i) Title I ADA discrimination by Tufts for offering an LTD plan with lesser mental-disability coverage; (ii) Title III ADA discrimination by MetLife as a “public accommodation” based on the plan’s terms; and (iii) ERISA violations challenging the mental-illness cap.

## Issues

1. Whether an employer violates Title I of the ADA by offering an LTD plan that caps benefits for mental disabilities at 24 months while providing longer benefits for physical disabilities.
2. Whether Title III of the ADA applies to an insurer’s administration of an employer-sponsored LTD plan so as to permit a challenge to the plan’s coverage terms.
3. Whether ERISA provides a cause of action to invalidate or override an LTD plan term that limits mental-disability benefits to 24 months when applied as written.

## Decision

- The court granted Tufts’s and MetLife’s motions to dismiss under Rule 12(b)(6) and dismissed all counts.
- Title I claim (Tufts): dismissed because offering a uniformly applied plan design that differentiates by category of condition (mental vs. physical) did not state ADA discrimination and fell within the ADA’s insurance safe harbor absent plausible allegations of prohibited pretext.
- Title III claim (MetLife): dismissed because Title III does not regulate the content of an employer-sponsored LTD policy; the claim challenged coverage terms rather than denial of access to a place of public accommodation.
- ERISA claim (Tufts and MetLife): dismissed because the complaint conceded termination occurred pursuant to the plan’s terms and ERISA does not impose substantive parity between mental and physical disability benefits or authorize rewriting plan design on that basis.

## Legal Principles

- Title I of the ADA does not require employers to provide equal levels of disability benefits for mental and physical conditions when the plan’s terms are facially uniform among employees and are not plausibly alleged to be a pretext for discrimination prohibited by the ADA.
- The ADA’s insurance safe harbor permits underwriting, risk classification, and administration consistent with state insurance law, subject to limits on using insurance as a pretext for otherwise unlawful discrimination.
- Title III of the ADA addresses discrimination in the enjoyment of goods and services of places of public accommodation and generally does not reach the substantive content of employer-provided insurance benefits.
- ERISA generally permits plan sponsors to define benefit levels and limitations; a claim under ERISA to “recover benefits due” ordinarily does not support invalidating plan terms where the administrator applied those terms as written.

## Conclusion

The court held that the challenged 24-month limitation on mental-disability benefits in an employer-sponsored LTD plan was a permissible plan-design feature for purposes of Title I ADA and ERISA, and that Title III ADA did not provide a vehicle to contest the content of the plan’s coverage terms, requiring dismissal of all claims.


Fletcher v. Tufts Univ., 367 F. Supp. 2d 99 (D. Mass. 2005)