Today, June 20, 2025, in Stanley v. City of Sanford, Florida case, the U.S. Supreme Court affirmed the Eleventh Circuit’s decision that retirees cannot bring claims under the Americans with Disabilities Act (ADA) for post-employment benefit changes. The Court held that ADA protections apply only to “qualified individuals” who currently hold or seek a position with an employer. Once an employee retires, these protections no longer apply.
The ADA requires employers to provide reasonable accommodations to qualified employees and applicants with disabilities. A “qualified individual” is someone who meets the necessary skill, experience, education, and other job-related requirements of a position and can perform the essential functions of the job, with or without reasonable accommodation. When an accommodation is requested, the employer must engage in an interactive process to identify an appropriate solution. The law also prohibits employers from discriminating against individuals with disabilities in any aspect of employment, including hiring, promotion, termination, compensation, training, and other terms or conditions of employment.
Karyn Stanley, a firefighter for the City of Sanford for nearly 19 years, retired in 2018 due to Parkinson’s Disease. When she was hired in 1999, the City provided disability retirees with free health insurance until age 65. However, in 2003, the City changed its policy, limiting the benefit to 24 months after retirement. Unaware of this change, Stanley filed suit in 2020 just before her coverage was set to end claiming the policy violated Title I of the ADA, which prohibits disability-based discrimination in compensation and fringe benefits. Both the district court and the Eleventh Circuit dismissed her case, holding that Title I applies only to current employees and job applicants.
Writing for the majority, Justice Neil M. Gorsuch explained that to bring a claim under Title I of the ADA, plaintiffs must show that they either held or applied for a job and were able to perform its essential functions, with or without reasonable accommodation, at the time of the alleged discrimination. In Stanley’s case, the reduction in her healthcare benefits occurred in 2020, two years after she retired. Because she was no longer employed when the alleged discrimination occurred, she did not meet the criteria of a “qualified individual” under the ADA and, therefore, was not protected by Title I. Justice Gorsuch emphasized that the ADA is intended to “protect people, not benefits,” from discrimination.
The Supreme Court’s decision in Stanley makes clear that the ADA’s protections apply only to individuals who are currently employed or actively seeking employment. Once the employment relationship ends, those protections no longer apply.
If you have any questions about the ADA, state or local disability laws, or any other employment law matter, please contact Michael A. Airdo at mairdo@airdowerwas.com or James C. Jansen at jjansen@airdowerwas.com.