Minor v. Sun Life Assurance Company of Canada

CourtDistrict Court, N.D. Alabama
DecidedJune 2, 2025
Docket7:24-cv-01035
StatusUnknown

This text of Minor v. Sun Life Assurance Company of Canada (Minor v. Sun Life Assurance Company of Canada) is published on Counsel Stack Legal Research, covering District Court, N.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Minor v. Sun Life Assurance Company of Canada, (N.D. Ala. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA WESTERN DIVISION

JOCELYN MINOR, ] ] Plaintiff, ] ] v. ] 7:24-cv-1035-ACA ] SUN LIFE ASSURANCE COMPANY ] OF CANADA, et al., ] ] Defendants. ]

MEMORANDUM OPINION

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. (Doc. 8). Defendants move to dismiss all of Ms. Minor’s claims against them. (Docs. 18, 20). The court WILL GRANT IN PART, WILL DENY IN PART, and WILL FIND AS MOOT IN PART Sun Life’s motion. (Doc. 20). The court WILL DENY Sun Life’s motion to dismiss the ADA claim on the ground Ms. Minor lacks Article III standing. But the court WILL GRANT Sun Life’s motion to dismiss the ADA claim on the ground that Sun Life is not a “covered entity” and WILL DISMISS that claim WITH PREJUDICE. Because the court resolves the only claim over which it has original jurisdiction, the court WILL DECLINE to exercise supplemental jurisdiction over the remaining state law claims pursuant to 28 U.S.C. § 1367(c)(3) and WILL REMAND those claims to the Circuit Court of Tuscaloosa

County, Alabama. Accordingly, the court WILL FIND AS MOOT Sun Life’s motion to dismiss the state law claims against it (doc. 20 at 7–10, 12–14), and Ms. Miller-Ballard’s motion to dismiss Ms. Minor’s state law claims (doc. 18).

I. BACKGROUND In considering a Federal Rule of Civil Procedure 12(b)(6) motion to dismiss for failure to state a claim, the court must accept as true the factual allegations in the complaint and construe them in the light most favorable to the plaintiff. Butler v.

Sheriff of Palm Beach Cnty., 685 F.3d 1261, 1265 (11th Cir. 2012). Sun Life and Ms. Minor ask the court to consider extrinsic evidence in its Rule 12(b)(6) analysis. (See doc. 20 at 5; doc. 26 at 11–12). But in ruling on a Rule 12(b)(6) motion to

dismiss, the court is generally limited to the pleadings. See Fed. R. Civ. P. 12(d). Although the court may consider evidence outside the pleadings if the evidence is of undisputed authenticity and central to the claims made in the pleading, Johnson v. City of Atlanta, 107 F.4th 1292, 1300 (11th Cir. 2024), the declarations from

employees of Sun Life and Lear Corporation (see doc. 20 at 5) (citing doc. 10-2 at 2; doc. 20-1), and Lear Corporation’s position statement in response to Ms. Minor’s EEOC charge (doc. 26 at 11–12) (citing doc. 26-1), are not central to Ms. Minor’s

ADA claim. Therefore, the court is limited to Ms. Minor’s allegations in resolving Sun Life’s Rule 12(b)(6) challenge to the ADA claim. See Johnson, 107 F.4th at 1300.

In ruling on a Rule 12(b)(1) motion to dismiss for lack of subject matter jurisdiction, the court may “weigh the evidence and satisfy itself as to the existence of its power to hear the case.” Lawrence v. Dunbar, 919 F.2d 1525, 1529 (11th Cir.

1990). Accordingly, because Sun Life moves to dismiss under both Rule 12(b)(6) and Rule 12(b)(1), the court will separate the facts into: (1) those alleged by Ms. Minor, which the court relies on to resolve Sun Life’s Rule 12(b)(6) challenge to the ADA claim; and (2) extrinsic evidence presented by the parties that relates to

Ms. Minor’s Article III standing, which, together with Ms. Minor’s alleged facts, the court will rely on to resolve Sun Life’s Rule 12(b)(1) challenge to the ADA claim. a. Facts Alleged by Ms. Minor

In October 2023, Lear Corporation hired Ms. Minor as a human resources specialist. (Doc. 8 ¶ 8). Sun Life provides Lear Corporation employees with access to short-term disability benefits that employees can claim if they suffer from “brief illnesses.” (Id. ¶¶ 6, 9). Sun Life also approves disability and Family and Medical

Leave Act requests on behalf of Lear Corporation. (Id. ¶ 12). Ms. Minor suffers from Crohn’s disease and began experiencing severe symptoms related to that disease in February 2024. (Id. ¶¶ 15, 19). She “decided to

seek a medical leave of absence” and “requested income replacement benefits under the short-term disability policy . . . insured by Sun Life.” (Doc. 8 ¶¶ 20–21). Although Sun Life had at first approved Ms. Minor’s requests for leave and short

term disability, an employee at Lear Corporation “urged [Sun Life] to deny the [requests],” so Sun Life denied them “despite [Ms. Minor’s] eligibility.” (Id. ¶¶ 7, 23–25, 33–34). Lear Corporation then terminated Ms. Minor “because she was

allegedly on leave when she should not have been.” (Id. ¶ 35). b. Extrinsic Evidence Both parties present extrinsic evidence that is relevant to Sun Life’s jurisdictional challenge to Ms. Minor’s ADA claim. See Lawrence, 919 F.2d at 1529.

Sun Life includes: (1) a declaration from a case specialist employed by Sun Life, stating that Ms. Minor submitted a claim to Sun Life only requesting short-term disability benefits, not disability-related leave (doc. 20-1 at 3 ¶¶ 8–9); and (2) a copy

of the short-term disability claim Ms. Minor submitted to Sun Life on February 13, 2024, which does not include requests for leave or an accommodation (id. at 29–32). Ms. Minor attaches Lear Corporation’s position statement in response to Ms. Minor’s charge with the Equal Employment Opportunity Commission

(“EEOC”). (Doc. 26-1). In the position statement, Lear Corporation explains that Ms. Minor “sought to take a leave of absence through Sun[ ]Life on or about February 13, 2024” and “was initially granted two (2) weeks of leave pending

approval of additional leave documentation.” (Doc. 26-1 at 2). But Ms. Minor’s “leave remained pending because of insufficient medical documentation,” and Sun Life “required additional information in order to . . . approve the leave.” (Id.).

Nonetheless, Ms. Minor “was afforded all the leave that Sun[ ]Life approved without additional documentation.” (Id. at 5). II. DISCUSSION

Below, the court will address Sun Life’s Rule 12(b)(1) challenge to Ms. Minor’s ADA claim, followed by Sun Life’s Rule 12(b)(6) challenge to the ADA claim, and Defendants’ motions to dismiss Ms. Minor’s state law claims. a. Sun Life’s Rule 12(b)(1) Challenge to the ADA Claim

A defendant challenging the court’s subject matter jurisdiction over a case may seek dismissal “by either facial or factual attack.” Stalley ex rel. U.S. v. Orlando Regl Healthcare Sys., Inc., 524 F.3d 1229, 1232 (11th Cir. 2008). A facial attack

accepts as true the facts alleged in the complaint, requiring the court to determine only whether those facts sufficiently allege a basis for subject matter jurisdiction. Id. at 1232–33. “By contrast, a factual attack on a complaint challenges the existence of subject matter jurisdiction using material extrinsic from the pleadings, such as

affidavits or testimony.” Id. at 1233. In this case, Sun Life makes a factual attack. (See doc. 20 at 6) (inviting the court to consider extrinsic evidence in making the jurisdictional determination). “If a jurisdictional challenge . . .

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