Rebecca Holland, a Maine school employee, sued Elevance after its subsidiary Anthem denied coverage for FDA-approved weight-loss medications Wegovy and Contrave prescribed to treat her obesity. Holland alleged the health plan's exclusion for 'weight loss medications' violated Section 1557 of the Affordable Care Act by discriminating against plan enrollees diagnosed with obesity, seeking to represent a class of similarly affected individuals.
Circuit Judge Montecalvo rejected Holland's theories of proxy, intentional, and disparate impact discrimination, explaining that the exclusion applies to all enrollees seeking weight-loss medication coverage regardless of disability status. 'On its face, the [E]xclusion does not turn on disability status, impacts participants whether they are disabled or not, and does not isolate disabled participants for discriminatory treatment,' the court noted, finding Holland failed to demonstrate a sufficiently close 'fit' between individuals with obesity and those requiring prescription weight-loss medications.
The District of Maine originally dismissed Holland's putative class action in April 2025, with Judge Lance Walker determining her discrimination allegations were conclusory and conjectural. The district court noted that whether a health condition results in disability under the Americans with Disabilities Act requires an 'individualized inquiry' rather than a formulaic analysis based on diagnosis and prescription alone.
The ruling clarifies the pleading standards for disability discrimination claims under Section 1557 and may impact similar challenges to health plan exclusions. The decision comes as weight-loss medications like Wegovy have gained prominence for treating obesity, raising questions about insurance coverage obligations for these treatments in employer-sponsored health plans.