Phelps v. Field Real Estate Co.
United States Court of Appeals for the Tenth Circuit
991 F.2d 645 (10th Cir. 1993)
John Phelps (plaintiff), a real-estate manager who consistently missed his supervisor Poole's sales targets, was diagnosed with AIDS in 1986 and his condition was anonymously disclosed to Poole in 1988; Poole was satisfied by a doctor's note that Phelps could still work, but over 14 months later, after continued poor sales and a company reorganization, Field discharged Phelps. Phelps sued under ERISA Section 510, claiming the discharge was meant to interfere with his benefits, and the district court found insufficient evidence of that intent.
Whether an employer discriminates under ERISA by discharging an employee receiving health benefits absent proof the employer was motivated by intent to interfere with those benefits.