Case Presented Genuine Dispute Whether Bipolar Disorder Qualifies As A Physical Rather Than A Mental Disorder
Jane G. Fitts was an attorney at the Federal National Mortgage Association (“Fannie Mae”) until 1995, when bipolar disorder prevented her from working. Fitts applied for disability benefits under Fannie Mae's long-term disability insurance plan. Unum Life Insurance Company of America administered the plan. Unum paid Fitts but informed her that her benefits would end after two years pursuant to a clause in the plan limiting benefits “for disability due to mental illness.”
The plan defines “mental illness” as “mental, nervous or emotional diseases or disorders of any type.” Fitts complained that bipolar disorder is a physical illness, not a mental illness. Unum disagreed. Fitts then sued Unum under the Employee Retirement Income Security Act of 1974 (“ERISA”) for “benefits due under the terms of the plan.”
The district court granted summary judgment to Fitts on the ground that bipolar disorder is not a mental illness. On appeal, the D.C. Circuit vacated that order, finding that there was a genuine dispute about whether bipolar disorder qualifies as a physical rather than a mental disorder.
Fitts v. Unum Life Ins. Co. of Am.
The D.C. Circuit Court of Appeals’ jurisdiction includes federal administrative agencies and the Tax Court.