Winslow v. IDS Life Insurance Co.

IDS Life Insurance Company (defendant) automatically denied long-term disability insurance to applicants who reported being treated for mental or nervous conditions within the prior 12 months, letting them reapply a year after their last treatment. It denied Winslow (plaintiff) on that basis. Winslow asked IDS to reconsider, noting she had only mild symptoms, had never been hospitalized, and had never missed work, but IDS again denied her. Winslow sued under the Americans with Disabilities Act (ADA) and state law, seeking declaratory and injunctive relief and damages. IDS argued its policy reflected industry experience that depression-related care generated the most claims, and it invoked defenses under the McCarran-Ferguson Act and Title III's safe harbor. IDS moved for summary judgment.

Whether it violates the Americans with Disabilities Act for an insurer to uniformly deny a long-term disability insurance policy based on an applicant's mental-health disability.