Magazine article Developments in Mental Health Law
Classification of Bipolar Disorders and Depression as Mental Disorders Upheld, Thereby Defeating Claims Seeking Long-Term Disability Benefits
A federal court in New York ruled that the administrator of a long-term disability benefit plan did not act unreasonably when it categorized a claimant's bipolar disorder as a mental rather than a physical disability and thereby limited the claimant's benefits to a maximum of 18 months. If her disorder had been classified as a physical disability she was entitled to benefits through the age of 65. The claimant had argued that her bipolar disorder was a physical disease because the disorder is rooted in the complex biochemical processes that occur within the brain.
While acknowledging that a bipolar disorder may have a physical cause and that medical authorities may ultimately determine that it is a physical condition, the court determined that the administrator was entitled to considerable deference in making the classification and that it was not unreasonable to determine that it was a mental disability given that it is listed in the Diagnostic and Statistical Manual of Mental Disorders IV (DSM-IV). The court was not dissuaded by the caveat contained in the DSM-IV's introduction that many disorders classified as mental disorders have physical components and that distinguishing between mental and physical disorders is a reductionistic anachronism. Fuller v. J.P. Morgan Chase & Co. Benefits Appeal Comm. …