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Kolton v. County of Anoka6/13/2002
We are asked to decide whether an employer that provides at no cost to its employees a long-term disability plan that limits benefits for disability due to mental illness to 24 months unless the employee is confined to a hospital or an institution licensed to provide psychiatric treatment, but does not so limit benefits for physical disabilities, discriminates because of disability in violation of the Minnesota Human Rights Act (MHRA), Minn. Stat. §á363.03, subd. 1(2)(c) (2000), or violates the right to equal protection under the Minnesota and United States Constitutions. We conclude that such an employer does not discriminate because of disability in violation of the MHRA and does not violate the right to equal protection under the Minnesota and United States Constitutions.
The parties agree that the material facts are not in dispute. In 1987, appellant County of Anoka added long-term disability (LTD) insurance to its employee benefits package. In 1994, the county solicited bids for LTD coverage and received proposals from nine companies. The proposals contained a distinction, standard in the industry, in benefits between mental and physical disabilities. The proposals limited benefits for disability due to mental illness to 24 months unless the employee was confined to a hospital or an institution licensed to provide psychiatric treatment, but did not contain a similar limitation on benefits for physical disabilities. Appellant Sun Life Insurance Company of Canada submitted the least expensive proposals and the county accepted one of them. The Sun Life policy selected by the county took effect on July 1, 1994. The county provided the policy to its employees, without regard to their physical or mental status, at no cost to them.
Respondent Gloria Kolton worked for Anoka County as an income maintenance specialist from December 1990 to October 1994. She resigned due to mental illness and has been disabled ever since. She received long-term disability benefits from Sun Life from April 1995 to April 1997. At the end of that 2-year period, Sun Life terminated her benefits because she was not confined to a hospital or an institution licensed to provide psychiatric treatment.
In early 1997, Kolton filed a charge of disability discrimination against Anoka County with the Equal Employment Opportunity Commission (EEOC). Later that year, the EEOC issued a determination that the county had violated Title I of the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. § 12112 (1994). After the EEOC determination, the county obtained additional LTD coverage that removed the limitation on benefits for disabilities due to mental illness, for which it paid an additional $28,000 in annual premiums.
Kolton filed suit against the county, alleging that it had violated the Equal Protection Clause, U.S. Const. amend. XIV, § 1, the right to equal protection under the Minnesota Constitution, Minn. Const. art. 1, § 2, the MHRA, Minn. Stat. § 363.03, subd. 1(2) (2000), and the ADA, 42 U.S.C. § 12112. The county filed a third-party complaint against Allan T. Roth, individually and doing business as A.T. Group, and Sun Life. Anoka County, Sun Life, and Roth (collectively, appellants) then moved to dismiss Kolton's complaint or, in the alternative, for summary judgment.
The district court granted appellants' motion for summary judgment and dismissed all of Kolton's claims. First, the district court applied rational basis review to Kolton's federal and state equal protection claims and found that the limitation on benefits for disability due to mental illness served the county's legitimate purpose of considering cost and economic factors when selecting its insurance polici
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