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Winslow v. IDS Life Insurance Co.

United States District Court, Minnesota
29 F.Supp.2d 557 (1998)


Facts

IDS Life Insurance Company (IDS) (defendant) denied Winslow’s (plaintiff) application based on its own practices of automatically denying long-term disability insurance to applicants who report being treated for mental or nervous conditions within 12 months prior to the submission of the application. The IDS practice allowed those affected applicants to re-apply one year after their last treatment for mental or nervous conditions. After being denied, Winslow asked IDS to reconsider, noting that she suffered only mild symptoms, had never been hospitalized, nor missed work due to her mental health condition. IDS re-visited Winslow’s application and again denied it. Winslow sued IDS in federal district court seeking declaratory and injunctive relief and for damages under the Americans with Disabilities Act (ADA) and state law. IDS asserted that its policy was based on an industry-wide experience that the highest number of claim payments was for depression-related care. Winslow argued that IDS’s practice of categorically denying applications differs from the policy stated in an underwriting manual it utilizes in making other policy determinations. IDS filed a motion for summary judgment.

Rule of Law

Issue

Holding and Reasoning (Davis, J.)

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