## Facts

- Ouida Sue Parker worked for Schering‑Plough Health Care Products, Inc. and participated in an employer-sponsored long-term disability (LTD) plan issued and administered by Metropolitan Life Insurance Co. (MetLife).
- The LTD plan capped benefits for “mental or nervous disorders” at 24 months (absent hospitalization or institutionalization) but provided benefits for “physical” disabilities until age 65.
- Parker became totally disabled due to severe depression and received LTD benefits for 24 months.
- MetLife classified Parker’s condition as a mental/nervous disorder and terminated benefits after 24 months under the plan limitation.
- Parker alleged (1) the plan’s shorter mental-disability benefit period unlawfully discriminated under the ADA and (2) MetLife’s classification of her depression as mental/nervous was arbitrary and capricious under ERISA.

## Issues

1. Whether Parker could pursue an ADA Title I claim challenging LTD plan terms when she was totally disabled and could not perform her job’s essential functions.
2. Whether ADA Title III applies to the terms of an employer-provided LTD plan, including benefit limits that differentiate between mental and physical disabilities, and whether the insurer/administrator is a “public accommodation” for that purpose.
3. Whether MetLife acted arbitrarily and capriciously under ERISA in classifying Parker’s disabling depression as a mental/nervous disorder subject to the 24-month cap.

## Decision

- The Sixth Circuit (en banc) affirmed judgment for MetLife and Schering‑Plough on all claims.
- Title I: Parker could not proceed because she was not a “qualified individual with a disability” when she was unable to perform the essential functions of her position.
- Title III: The court held Title III does not reach the substantive terms of an employer-provided LTD plan as alleged and does not require parity between mental and physical disability benefits in that setting.
- ERISA: The court upheld the plan administrator’s classification decision under a deferential arbitrary-and-capricious standard.

## Legal Principles

- ADA Title I protects only a “qualified individual with a disability,” i.e., someone who can perform essential job functions with or without reasonable accommodation.
- ADA Title III’s “public accommodation” provisions are tied to access to a place of public accommodation and do not, in this context, regulate the content of employer-provided insurance benefits.
- The ADA’s insurance provision permits insurers to underwrite, classify, and administer risks consistent with state law, barring use of such practices as a subterfuge to evade the ADA.
- Under ERISA, when a plan grants discretionary authority to interpret plan terms and determine eligibility, a court upholds the administrator’s decision if it is reasonable (arbitrary-and-capricious review).

## Conclusion

The en banc Sixth Circuit held that Parker could not sue under ADA Title I because she was not able to work, and that ADA Title III did not apply to the substantive terms of her employer’s LTD plan to require equal benefit durations for mental and physical disabilities; the court also sustained MetLife’s mental-disability classification under ERISA’s deferential review standard.


Parker v. Metro. Life Ins. Co., 121 F.3d 1006 (6th Cir. 1997) (en banc)