Parker v. Metropolitan Life Insurance Co.

Ouida Parker (plaintiff) was employed by Schering-Plough Health Care Products, Inc. (Schering-Plough) and participated in a long-term-disability (LTD) plan offered by Schering-Plough and issued by Metropolitan Life Insurance Company (MetLife) (defendant). Under the plan, those with total mental disabilities could receive benefits for up to 24 months, at which point the benefits expired unless the person was hospitalized or institutionalized for the disability. In contrast, enrolled people with total physical disabilities could receive benefits until age 65. Parker became disabled due to severe depression, and her benefits were terminated after 24 months in compliance with the plan’s terms. Parker filed suit in federal district court against MetLife, arguing that the differentiated benefits for mental and physical disabilities constituted discrimination under Title I and Title III of the Americans with Disabilities Act (ADA). The district court found in favor of MetLife, and Parker appealed to the Sixth Circuit. A panel of the Sixth Circuit affirmed the trial court’s ruling on the Title I claim but reversed the court’s ruling on the Title III claim. MetLife petitioned for a rehearing by the Sixth Circuit. On rehearing, the appellate court affirmed the district court’s ruling that MetLife did not violate Title I and readdressed whether MetLife’s plan offerings violated Title III.