Carparts, et al. v. Auto Wholesalers

CourtDistrict Court, D. New Hampshire
DecidedSeptember 30, 1997
DocketCV-92-592-M
StatusPublished

This text of Carparts, et al. v. Auto Wholesalers (Carparts, et al. v. Auto Wholesalers) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carparts, et al. v. Auto Wholesalers, (D.N.H. 1997).

Opinion

Carparts, et al. v. Auto Wholesalers CV-92-592-M 09/30/97 P UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Carparts Distribution Center, Inc., Daniel Drish and Shirley M. Senter, Co-Executors of the Estate of Randv J. Senter, and the Equal Employment Opportunity Commission,

Plaintiffs

v. Civil No. C-92-592-M

Automotive Wholesaler's Ass'n of New England, Inc., and Automotive Wholesaler's Ass'n of New England, Inc. Insurance Plan.

Defendants

O R D E R

Plaintiffs bring this action pursuant to Titles I and III of

the Americans with Disabilities Act of 1990, Title I of the Civil

Rights Act of 1991, and 42 U.S.C. § 1985(3), seeking damages for

alleged acts of unlawful discrimination in the administration of

certain health insurance benefits claimed by the Estate of Randy

Senter. The complaint also alleges several statutory and common

law causes of action under the law of the State of New Hampshire.

Pending before the court are plaintiffs' motion for summary

judgment on their claims under Title I of the ADA and defendants'

motion for summary judgment as to all of plaintiffs' claims.

Factual Background Prior to his death, Randy Senter was the sole shareholder,

president, and an employee of Carparts Distribution Center, Inc.,

an automotive parts wholesaler located in Plaistow, New

Hampshire. In May of 1986, Senter learned that he was infected

with the Human Immunodeficiency Virus ("HIV"). Approximately

five years later, he was diagnosed as suffering from Acguired

Immune Deficiency Syndrome ("AIDS"). He died on January 17,

1993.

In 1977, Carparts became a participant in a self-funded

medical cost reimbursement plan known as Automotive Wholesaler's

Association of New England Health Benefit Plan (the "Plan"),

which was offered by defendants Automotive Wholesaler's

Association of New England, Inc. ("AWANE") and its administering

trust. Automotive Wholesaler's Association of New England, Inc.

Insurance Plan (the "Trust"). As an employee of Carparts, Senter

enrolled in the Plan in 1977, which, at the time, provided

lifetime medical insurance benefits in the amount of $1,000,000

per eligible member. In January of 1991, however, defendants

instituted a $25,000 cap on lifetime benefits for AIDS-related

illnesses. Plaintiffs claim that defendants instituted the cap

with knowledge that Senter was HIV positive, suffering from AIDS,

and incurring AIDS-related medical expenses. Defendants deny any

2 knowledge of Sender's illness prior to implementation of the cap.

They also deny that their conduct is prohibited by the ADA.

In 1993, this court (Loughlin, J.) dismissed plaintiffs'

complaint, concluding that the ADA does not apply to this case

because defendants were neither Senter's "employers" under Title

I nor were they "public accommodations" under Title III.1 The

court also concluded that plaintiffs "failed to identify a source

of congressional power other than the Americans with Disabilities

Act so as to reach the private conspiracy alleged by plaintiffs."

Finally, the court dismissed plaintiff's state law claims as

preempted by the provisions of ERISA. Carparts Distribution

Center, Inc. v. Automotive Wholesaler's Ass'n of New England,

Inc., No. C-92-592-L, slip op. (D.N.H. July 19, 1993) ("Carparts

I") •

On appeal, the Court of Appeals for the First Circuit held

that Judge Loughlin had interpreted the provisions of Title I and

Title III of the ADA too narrowly and erred in dismissing

This case presents a somewhat unusual situation insofar as Carparts, Senter's employer, is a plaintiff, rather than a defendant. Apparently, when the Plan refused to reimburse Senter for certain AIDS-related medical treatment, Carparts paid for some of his medical expenses. Accordingly, Carparts, like Senter's estate, claims to have suffered damages as a result of defendants' allegedly wrongful conduct.

3 plaintiffs' complaint. With regard to Title I of the ADA, the

court of appeals observed that "defendants could be considered

Sender's 'employers,' and therefore subject to liability under

Title I, under any one of at least three theories." Carparts

Distribution Center, Inc., v. Automotive Wholesaler's Ass'n of

New England, Inc., 37 F.3d 12, 14 (1st Cir. 1994) ("Carparts

II"). With regard to Title III of the ADA, the court concluded

that "public accommodations" are not limited to physical

structures. Id. at 19. Accordingly, the appellate court

reasoned that Title III of the ADA may well prohibit self-insured

group health benefit plans from discriminating against protected

individuals with regard to the content of the goods and/or

services they provide.

The court of appeals then remanded the case with

instructions to reconsider plaintiffs' claims in light of its

opinion. Upon Judge Loughlin's retirement, the case was

reassigned to this judge.

Discussion

I. Jurisdiction Over Plaintiffs' Title I Claims.

At this juncture, the existence of unresolved factual issues

(and undeveloped legal arguments), preclude the court from

4 determining whether it has jurisdiction over plaintiffs' Title I

claims. Although alluded to in the parties' papers, the

following issue remains largely unaddressed: Provided defendants

may, under the tests articulated by the court of appeals in

Carparts II, properly be deemed to be Senter's "employer" for

purposes of the ADA (which seems likely), did that "employer"

have "25 or more employees for each working day in each of 20 or

more calendar weeks." 42 U.S.C. § 1211(5). Obviously, that

guestion raises another: Whether this court should count the

number of individuals employed by the plaintiff, Carparts

(Senter's actual employer, which appears to have employed more

than 25 individuals), or the number employed by defendants, AWANE

and/or the Trust (Senter's constructive "employers" for purposes

of Title I, neither of which appears to have employed 25 or more

individuals) .

Resolution of that guestion (which turns on not only legal

issues, but factual ones as well) will obviously determine

whether Title I of the ADA properly governs defendants' conduct

in this case and whether the court has jurisdiction over

plaintiffs' Title I claims. Accordingly, on or before November

14, 1997, the parties shall file memoranda addressing that issue,

providing appropriate citation to any relevant legal authority

5 (binding or persuasive). Additionally, the parties shall brief

the following legal and factual guestions:

1.

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