Carparts Distribution Ctr. v. Auto. Wholesaler's Ass'n - 37 F.3d 12 (1st Cir. 1994)

Rule:

A defendant would be rendered an "employer" under the Americans with Disabilities Act (ADA), 42 U.S.C.S. § 12101 et seq. if it is an agent of a covered entity, who acts on behalf of the entity in the matter of providing and administering employee health benefits. Just as delegation of responsibility for employee benefits cannot insulate a discriminatory retirement benefits plan from attack under Title VII of the Civil Rights Act of 1964, neither can it insulate a discriminatory health benefits plan under Title I of the ADA.

Facts:

Plaintiff AIDS victim and his employer brought an action against defendant health plan, alleging that a lifetime cap on health benefits for individuals with AIDS instituted by the health plan represented illegal discrimination on the basis of a disability. The United States District Court for the District of New Hampshire dismissed plaintiffs’ claims under Fed. R. Civ. P. 12(b)(6). Plaintiffs appealed. 

Issue:

Under the circumstances, was the district court’s dismissal erroneous as a matter of law?

Answer:

Yes.

Conclusion:

The court held that the district court erred in dismissing AIDS victim's claims pursuant to Fed. R. Civ. P. 12(b)(6) without giving him notice and a chance to respond. The court further held that the district court erred in holding that the Americans with Disabilities Act, 42 U.S.C.S. § 12101 et seq., did not apply to AIDS victim's health care plan because the plan was not an "employer" under the Act. The court held that AIDS victim should have been given the opportunity to plead and develop facts under which his employer's health care plan might have been deemed to be an employer. The court held that the district court erred in dismissing AIDS victim's public accommodation claim as well, because Congress did not intend for Title III of the Act to apply only to physical structures.