The U.S. Supreme Court ruled that a retired fighter with Parkinson’s disease is barred from bringing a claim under the Americans with Disabilities Act (“ADA”) over her post-employment health benefits because the ADA only covers employees who are “qualified individuals.” (Stanley v. City of Sanford (2025)145 S.Ct. 2058, 222 L.Ed.2d 331.)
Karyn Stanley, a former firefighter for the City of Sanford, Florida retired early when she developed Parkinson’s disease. The City of Sanford offered health insurance until age sixty-five for employees with at least twenty-five years of service or for a limited period for employees who retired early due to disability. In 2003, the City changed its policy for employees taking early disability retirement by providing health insurance coverage for only twenty-four months. After receiving health insurance subsidies from the City for twenty-four months, Stanley’s health insurance subsidies ended, prompting Stanley to file a lawsuit alleging that the City discriminated against disabled retirees in violation of Title 1 of the ADA.
The Supreme Court’s holding in Stanley focused on the definition of a “qualified individual” under Title 1 of the ADA. Under the ADA, qualified individuals are individuals “who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individuals holds or desires.” (42 U.S.C § 1211(8).) Justice Gorsuch held that the present-tense language of the ADA meant “that the statute does not reach retirees who neither hold nor desire a job at the time of an alleged act of discrimination.” (Stanley, 145 S.Ct. 2058, at 2064.) For example, the present-tense verbs such as “discriminate against,” “can perform,” “holds or desires” signal that the ADA only “protects individuals who, with or without reasonable accommodation, are able to do the job they hold or seek at the time they suffer discrimination.” (Id.) It does “not reach retirees who neither hold nor desire a job at the time of an alleged act of discrimination.” (Id.) The Supreme Court further concluded that a “qualified individual” is a person who is currently employed or seeking employment and able to perform the essential duties of the job. And in this case, the ADA did not apply to Stanley since, at the time the City ceased her health insurance benefits, she no longer worked as a firefighter, did not desire reemployment, and could not perform the essential functions of a firefighter.
The Stanley decision narrows the scope of standing for retired employees when bringing claims under the ADA. Now, in order to have standing under the ADA, the plaintiffs must have a job and disability at the time of the alleged disability discrimination, not when they have already retired.
In order to best mitigate against litigation risk, it is important for employers to understand what they can and cannot do with respect to benefits involving health coverage, disability, and retirement. Please feel free to contact us if you have questions about these topics.