Recent cases have radically changed the scope of the American with Disabili
ties Act (ADA), fundamentally altering and reshaping protections for the di
sabled. In light of the Seventh Circuit's controversial opinion in Doe v. M
utual of Omaha, there is a pressing need for a clear standard to define wha
t medical care legally can be excluded from insurance coverage. in this Not
e, Jennifer Geetter argues that ail approach seeking a correlative and caus
ation relatedness standard steered by impartial medical science would bette
r serve the interests of insureds and would provide insurance companies wit
h a clear outline of their privileges and limitations.