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Erickson v. The Bartell Drug Company

United States District Court for the Western District of Washington

141 F. Supp. 2d 1266 (2001)

Facts

The Bartell Drug Company (Bartell) (defendant) offered a generally comprehensive prescription drug plan to its employees. However, Bartell’s plan excluded prescription contraceptives. Jennifer Erickson (plaintiff) was an employee at Bartell and brought suit, asserting that Bartell’s decision not to cover contraceptives violated Title VII of the Civil Rights Act. Bartell offered a number of arguments as to why its failure to cover contraceptives did not violate Title VII. Among other contentions, Bartell claimed that because contraceptives were voluntary, preventative, and do not treat or prevent disease, they are not truly healthcare-related and thus can be treated differently from other prescription drugs. Bartell also argued that it should be permitted to limit the scope of its employee-benefit programs in order to control costs. The United States District Court for the Western District of Washington heard the case.

Rule of Law

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Issue

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Holding and Reasoning (Lasnik, J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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