In the recent U.S. Supreme Court case Stanley v. City of Sanford, Florida, the Court clarified a critical point regarding the scope of the Americans with Disabilities Act (ADA). Writing for the 7-2 majority, Justice Neil Gorsuch held that Title I’s employment discrimination protections do not extend to individuals who have retired and are no longer employed or seeking employment. This ruling marks a clear win for employers, establishing that retirees who do not hold or seek employment are not “qualified individuals” under the ADA and therefore cannot sustain claims under the statute.
Case Background
Karyn Stanley, a former firefighter with the City of Sanford, Florida, was compelled to retire in 2018 due to a disability. Under a revised city policy implemented in 2003, employees who retired because of a disability were entitled to only 24 months of health insurance coverage, whereas those who retired after 25 years of service enjoyed coverage until age 65. Stanley filed suit under the ADA, alleging that this policy discriminated against her based on her disability.
Notably, Stanley’s lawsuit was filed in 2020—approximately two years after her retirement and just months before her benefits were scheduled to end. The timing is significant, as the outcome might have differed had she initiated the claim while still employed.
The Supreme Court’s Holding: Textual Limits on ADA Title I
The Court affirmed the Eleventh Circuit’s dismissal of Stanley’s claim, reiterating that Title I of the ADA protects only “qualified individuals” — those who currently “hold or desire” a job and can perform its essential functions. The Court underscored Congress’s deliberate use of present-tense language in the statute, specifying that an individual must be able to “perform the essential functions” of the job with or without reasonable accommodation at the time discrimination allegedly occurs. This statutory framework excludes individuals who have already left the workforce and are not actively seeking re-employment.
Justice Gorsuch addressed arguments that retirees might still be covered because they once held a job, stating plainly, “The statute protects people, not benefits, from discrimination.” He emphasized that Title I is intended to prevent workplace discrimination against qualified individuals—not to regulate post-employment benefits for retirees.
Practical Implications for Employers
This ruling provides a crucial clarification: the ADA’s employment protections have defined limits. To bring a successful ADA claim, an individual must be a current employee or applicant capable of performing the essential functions of the job. Retirees, by definition, cannot satisfy this qualification requirement if they are no longer working or seeking work. Moreover, Stanley’s case illustrates how timing matters significantly—filing after retirement severely weakens an ADA claim under the statute’s plain language.
The Court also made clear that its decision does not preclude other legal claims that might arise under different laws, such as the Rehabilitation Act, state statutes, or constitutional equal protection claims. However, the Court firmly rejected expanding ADA Title I protections to retirees beyond the statute’s explicit text.
Conclusion
Our DC Employment attorneys see the Stanley decision reinforces an important principle for employers: the ADA’s protections under Title I apply strictly to employees or applicants who are “qualified” — meaning they can perform the essential functions of the position they hold or seek. The Supreme Court’s ruling clarifies that retirees are not considered qualified individuals under the ADA since they do not desire or hold employment.
While employers remain responsible for accommodating current employees and applicants under the ADA, this decision offers a degree of certainty concerning retirees. Employers should continue to carefully draft and maintain accurate job descriptions that clearly define essential functions, positioning themselves to effectively defend against potential ADA claims in the future.