Fletcher v. Tufts University

Madeleine Fletcher (plaintiff) was a professor at Tufts University (Tufts) (defendant) until she was hospitalized and diagnosed with bipolar disorder. After five months of medical leave, Fletcher remained unable to work and shifted to long-term-disability (LTD) leave. As a Tufts employee, Fletcher received LTD benefits through Metropolitan Life Insurance Company (MetLife) (defendant). The terms of Fletcher’s LTD plan specified that any person who was disabled from a mental-health issue maxed out of LTD insurance after two years unless the person was institutionalized. The institutionalization requirement did not apply to people with physical disabilities. Pursuant to the plan’s requirement, MetLife terminated Fletcher’s LTD benefits after two years. A few months later, a return-to-work evaluation concluded that Fletcher’s continuing disability rendered Fletcher incapable of performing her essential job functions and that no accommodation would enable her to work. Based on the evaluation, Tufts terminated Fletcher’s employment. Fletcher sued Tufts and MetLife in federal district court, alleging that, by adopting an LTD plan that discriminated against people with mental-health disabilities, Tufts had violated Title I of the Americans with Disabilities Act (ADA) and MetLife had violated Title III of the ADA. Both Tufts and MetLife moved to dismiss Fletcher’s complaint. Tufts argued that it did not violate the ADA by selecting an LTD plan that distinguished between people with physical and mental disabilities. MetLife argued that Title III did not apply to employment benefit plans.