Minor v. Sun Life Assurance Company of Canada et al

Plaintiff Jocelyn Minor sued Defendants Sun Life Assurance Company of Canada and Stacey Miller-Ballard for discrimination in violation of the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12112(a), and various state law claims. Defendants moved to dismiss all claims. The U.S. District Court for the Northern District of Alabama denied Sun Life's motion to dismiss the ADA claim on Article III standing grounds, but granted the motion on the basis that Sun Life is not a "covered entity" under the ADA, dismissing that claim with prejudice. Having resolved the only claim over which it had original jurisdiction, the court declined to exercise supplemental jurisdiction over the remaining state law claims and remanded them to the Circuit Court of Tuscaloosa County, Alabama.

The court granted in part and denied in part Sun Life's motion to dismiss. The ADA claim was dismissed with prejudice because Sun Life is not a "covered entity" under the ADA. The court declined supplemental jurisdiction over the state law claims and remanded them to state court.

The central dispute was whether Sun Life Assurance Company of Canada qualifies as a "covered entity" under the Americans with Disabilities Act, and whether the court had subject matter jurisdiction over the ADA claim.

The ruling reinforces the principle that ADA liability is limited to "covered entities" such as employers, and does not extend to insurance companies merely administering benefits plans. It also demonstrates the federal courts' reluctance to retain supplemental jurisdiction over state law claims once federal claims are dismissed.