/>iIn, Stanley v. City of Sanford, Florida, the U.S. Supreme Court clarified the scope of the Americans with Disabilities Act, holding that Title I’s employment discrimination provisions do not apply to individuals who are retired and no longer hold or seek employment. The decision, a 7-2 majority written by Justice Neil Gorsuch, gives employers a clear win concerning retirees and the ADA, specifically that a retiree who is not holding or seeking employment is not a qualified individual under the ADA and therefore cannot bring a successful suit under that statute.
The Facts
Karyn Stanley, a former firefighter for the City of Sanford, Florida, was forced to retire in 2018 due to a disability. Under the city’s revised 2003 policy, employees who retired due to disability received only 24 months of health insurance, compared to those employees who retired with 25 years of service who received coverage until age 65. Stanley sued under the ADA, alleging the policy discriminated based on her disability.
Importantly, Stanley filed suit in 2020, about two years into her retirement and a few months before her benefits were about to be terminated. The outcome of the case may have been different if she brought suit while she was still employed.
The Ruling: Clear Textual Limits on Title I of the ADA
The decision affirmed the Eleventh Circuit’s dismissal of the claim, holding that Title I of the ADA protects only “qualified individuals”—those who hold or desire a job and can perform its essential functions. The court emphasized Congress’s use of present-tense language—“holds or desires” a position—and the statutory requirement that the person be able to “perform the essential functions” of the job with or without reasonable accommodation at the time the person allegedly suffers discrimination. This definition does not apply to individuals who have already exited the workforce and are not seeking re-employment at the time the individual suffers discrimination.
The court dismissed arguments that retirees are nonetheless covered because they once held a job. “The statute protects people, not benefits, from discrimination,” Gorsuch wrote, reinforcing the view that Title I is designed to prevent workplace discrimination against qualified individuals—not to govern post-employment benefits for retirees.
Why It Matters for Employers
The ruling reinforces that the ADA’s employment protections are not unlimited. To be able to assert an ADA claim, an employee or applicant must be able to perform the essential functions of the position held or desired. Retirees who are not working cannot, by definition, meet that threshold ADA requirement. Furthermore, the timing of Sanford’s suit – after she had already retired – ultimately doomed her ADA case when viewed in light of the ADA’s plain language.
The court was careful to note that its decision does not preclude other legal avenues, such as claims under the Rehabilitation Act, state law, or constitutional equal protection claims. But critically, ADA Title I cannot be stretched beyond its plain text to cover retirees.
Conclusion
The Stanley decision reinforces a principle many employers have long understood: that the ADA only applies to employees or applicants who are qualified, which means they can perform the essential functions of the job they hold or desire. The Supreme Court made it clear that a retiree cannot be qualified under Title I of the ADA because the retiree is not seeking to perform the essential functions of a job that he/she holds or desires. Employers still face potential ADA liability from current employees or applicants, and employers should review their job descriptions to make sure they are as accurate as possible and define the job’s essential functions to be in the best position to defend themselves against ADA claims in the future.
