Wednesday, November 13, 2013

Winslow v. IDS Life Insurance Co. case brief

Winslow v. IDS Life Insurance Co. case brief summary
29 F.Supp.2d 557 (1998)

Plaintiff customer had filed an action for declaratory and injunctive relief and for damages under the Americans with Disabilities Act (ADA), 42 U.S.C.S. § 12101 et seq., and the Minnesota Human Rights Act (MHRA), Minn. Stat. 363.01 et seq., after she was denied long-term disability insurance by defendant insurer because of her current history of treatment for a mental health condition. The insurer brought a motion for summary judgment.


The customer had indicated on her insurance application that she had been treated for mental illness, dysthymia or mild depression, within the last year.


  • The court found that when the customer was denied coverage the insurer considered her to be impaired and likely unable to perform a broad range of jobs. 
  • The court found that: 
  • (1) The subterfuge provision of the ADA, specifically 42 U.S.C.S. § 12201(c), prohibited the use of the safe harbor provision to evade the purposes of Title III of the ADA and was a statutory provision specifically related to the business of insurance; 
  • (2) An insurance office was considered a public accommodation for purposes of Title III of the ADA; 
  • (3) The McCarran-Ferguson Act, 15 U.S.C.S. §1012 et seq., did not invalidate or supersede the relevant Minnesota statutes and did not bar the customer's ADA claims; 
  • (4) There was a genuine issue of material fact as to whether the insurer's eligibility criteria violated Minnesota law; and 
  • (5) Granted the motion for summary judgment as to the customer's claim for punitive damages finding that under Minn. Stat. § 549.20, the insurer's action did not demonstrate willful indifference to the customer's rights.

The court granted the insurer's motion for summary judgment on the customer's claim for punitive damages under the MHRA and denied the motion in all other respects.

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