U.S. Supreme Court Limits Retirees’ Ability to Bring Disparate Treatment Suits Under the ADA
U.S. Supreme Court Limits Retirees’ Ability to Bring Disparate Treatment Suits Under the ADA
Brett Whitley, Associate
On June 20, 2025, the Supreme Court of the United States (the “Court”) decided Stanley v. City of Sanford,[1] affirming the dismissal of a complaint alleging a retiree’s claim of disparate treatment on the basis of her disability in violation of the Americans with Disabilities Act (“ADA”).[2] The Court held that the retiree’s claim must be dismissed because she was not a “qualified individual” under Title I of the ADA (“Title I”),[3] as she did not plead that she could perform the essential functions of the employment position that she held or desired. In so doing, the Court substantially limited retirees’ ability to enforce the protections articulated in Title I.
Brief Background
Karyn Stanley began working as a firefighter for the city of Sanford, Florida (“City”), in 1999. When she was hired, the City’s policy was to pay for health insurance up to age 65 for retirees with 25 years of service or those who could not work for 25 years due to a disability. However, in 2003, the City changed its policy to provide health insurance for just 24 months for those who could not work 25 years due to a disability. Ms. Stanley’s retired due to a disability in 2018. Under the City’s revised policy, that meant she was entitled to at most 24 months of health insurance. Ms. Stanley’s health insurance benefits therefore ended in 2020.
Ms. Stanley then brought suit against the City under Title I, alleging it was violating the ADA due to it discriminating on the basis of disability in the conferring different health insurance benefits to those who retire due to a disability prior to working 25 years.
Title I of the ADA
Title I makes it unlawful for a covered employer to “discriminate against a qualified individual on the basis of disability in regard to . . . compensation.” A “qualified individual” is someone “who, with or without reasonable accommodation, can perform the essential functions of the employment position that [she] holds or desires.”[4] Ms. Stanley and the City agreed that retirement benefits qualified as “compensation” within the meaning of Title I.
The Court’s Decision and Reasoning
The Court’s decision hinged on one issue: whether a retired employee who does not hold or seek a job is a “qualified individual” within the meaning of Title I. The Court held that Ms. Stanley did not plead that she was a “qualified individual” under Title I, as she did not plead that she held or desired a job when the alleged disability discrimination took place. In support for this holding, the Court focused on the present-tense verbs within the definition of “qualified individual,” like “can perform,” “holds,” and “desires.” According to the Court, these verbs signal that Congress did not intend Title I to protect retirees like Ms. Stanley who neither hold nor desire a job at the time of an alleged act of discrimination. The Court solidified its reasoning by pointing to Court precedent where it anticipated the possibility that someone may fall outside the protections of Title I if she can no longer perform her job. However, the Court suggested that a retiree could still bring a claim under Title I over post-employment benefits if the alleged discrimination happened while the person still held or desired a job, but that is not what Ms. Stanley plead here.
Key Takeaways/ Employer Considerations
Employers should not consider Stanley as the Court giving them the green light to take away retirement benefits from an employee once that employee retires. There are still numerous pieces of legislation that could prohibit such acts as the Employee Retirement Income Security Act. However, what Stanley tells employers is though the ADA’s workplace protections will likely not cover retirees if they are not holding or seeking a job with the employer. Therefore, if an employer were to change its policies in a manner that discriminates on the basis of one’s disability, an employer would be prudent to consult counsel like Campbell Litigation P.C. to determine if/how this change would affect “qualified individuals” or in other words, those in its workforce that with or without reasonable accommodation, can perform the essential functions of the employment position that he or she holds or desires.
[1] Stanley v. City of Sanford, 606 U.S. _____ (2025).
[2] Pub. L. No. 101-336, 104 Stat. 328 (1990).
[3] 42 U.S.C. § 12112(a).
[4] 42 U.S.C. § 12111(8).