/>iIn Stanley v. City of Sanford, Florida, the U.S. Supreme Court held a disabled former employee who neither “holds” nor “desires” a job is not a “qualified individual” under the ADA and, thus, cannot sue for disability discrimination following her employer’s revocation of retiree health benefits.
The plaintiff, Karyn Stanley, was a firefighter for the City of Sanford, Florida (“City”) who retired after she was diagnosed with Parkinson’s disease. When she joined the fire department, disabled retirees received free health insurance until they were 65 years old. While employed and unbeknownst to her, the benefit changed and disabled retirees were eligible for two years of coverage. Following her retirement, the plaintiff learned of the benefit change and received the two years of health insurance coverage.
Stanley, post-retirement, filed a lawsuit against the City alleging that the City violated the ADA and discriminated against her as a disabled retiree when it altered the health insurance plan. The district court dismissed her ADA claim. On appeal, the Eleventh Circuit affirmed, holding that, because Stanley had retired, she could not bring such a suit under the plain language of the statute. The Eleventh Circuit’s decision fell in line with three other circuits (Sixth, Seventh, and Ninth), while two other circuits (Second and Third) held that the ADA’s text is ambiguous and construed the statute in favor of employees.
The Court granted certiorari to determine “whether a retired employee who does not hold or seek a job is a ‘qualified individual.’” In a 7-2 opinion authored by Justice Gorsuch, the Court held that the plain language of the statute protects only “qualified individuals,” which is defined by the statute as those “who, with or without reasonable accommodation, can perform the essential functions of the employment position that [she] holds or desires.” The Court found that the present tense usage of “holds” and “desires” signals that the statute does not reach retirees. The Court found that other ADA provisions governing qualification standards and employment tests similarly convey that the statute “focus [is] on current and prospective employees—not retirees.” The Court also found it notable that the ADA’s retaliation provision protects “any individual,” and thus “different language in these two provisions strongly suggests that [Congress] meant for them to work differently.”
Rejecting arguments from the dissent that the “qualified individual” language could not have been meant to apply to retirees, the majority held that “we do not usually pick a conceivable-but-convoluted interpretation over the ordinary one.” The Court added: “we cannot say Title I’s textual limitations necessarily clash with the ADA’s broader purposes . . . . If Congress wishes to extend Title I to reach retirees like Ms. Stanley, it can.”
The last section of Gorsuch’s opinion was adopted by a four-justice plurality of the Court in which Gorsuch lost support from Justices Roberts, Thomas, Kavanaugh, and Barrett, but added support from dissenting Justice Sotomayor. The plurality addressed an additional question raised by Stanley in her merits briefing. While the Court admitted that it “ordinarily . . . rejects attempts to inject ‘an entirely new question at the merits stage,’” the plurality made “an exception in this case.” In short, the plurality explored potential avenues for retirees, like Stanley, to pursue similar ADA claims, but ultimately held that none provided relief to Stanley in the present procedural posture.
A key takeaway from Stanley is that a majority of the Court supports a textualist interpretation of the ADA even when an argument can be made that such an interpretation clashes with the broader purposes of the ADA.
