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Leonard F. v. Israel Discount Bank of New York

199 F.3d 99 (1999)

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Leonard F. v. Israel Discount Bank of New York

United States Court of Appeals for the Second Circuit
199 F.3d 99 (1999)

  • Written by Alexander Hager-DeMyer, JD

Facts

Leonard F. (plaintiff) was hired by Israel Discount Bank of New York (bank) (defendant) and provided with short-term-disability and long-term-disability (LTD) coverage issued by the Metropolitan Life Insurance Company (MetLife) (defendant). The LTD plan limited benefits to two years for individuals with mental disabilities but provided benefits up to age 65 for individuals with physical disabilities. Leonard became disabled due to depression and received short-term-disability benefits. Leonard eventually applied for and received LTD benefits that were cut off after the two-year time limit. Leonard filed suit against the bank and MetLife, claiming that both parties discriminated against him in violation of the Americans with Disabilities Act (ADA) by limiting mental-disability benefits and imposing no limits on physical-disability benefits. Leonard settled the matter with the bank, and the district court dismissed the case against MetLife for Leonard’s failure to state a claim and found that MetLife was protected by the safe-harbor provision in § 501(c) of the ADA. Leonard appealed to the Second Circuit.

Rule of Law

Issue

Holding and Reasoning (Leval, J.)

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