Supreme Court Clarifies Disability Discrimination Claim Requirements for Retired Employees

Factual Background

On June 20, 2025, the U.S. Supreme Court released its decision in the case of Stanley v. City of Stanford, Florida.

Plaintiff Karyn Stanley worked as a firefighter for the City of Stanford, Florida (the “City”) in various roles since 1999. At the time of Stanley’s hire, the City offered health insurance until age 65 for two categories of retirees: (1) those with 25 years of service for the City, and (2) those that retired due to disability. In 2003, the City revised this policy in that employees retiring due to disability received only 24 months of health insurance, not necessarily until age 65.

In 2018, Stanley retired due to a disability with less than 25 years of service and received 24 months of health insurance consistent with the policy that the City revised in 2003.

Stanley subsequently filed suit in federal court against the City under the Americans with Disabilities Act (the “ADA”), alleging disability discrimination due to the City providing different health insurance benefits for disabled retirees as compared with non-disabled retirees.  

Legal Background

The ADA prohibits employers from discriminating against a “qualified individual” on the basis of disability with respect to compensation and other matters. 42 U. S. C. §12112(a). The law defines a “qualified individual” as “an individual who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires.” §12111(8).

The central question of the Stanley case was whether a retired employee, in not currently holding or seeking a job with an employer, is a “qualified individual” entitled to protection under the ADA.

The District Court granted the City’s motion to dismiss, concluding that Stanley was unable to allege that she was a “qualified individual” at the time the discrimination allegedly occurred because she no longer worked at the City nor was she seeking a position of employment with the City.

The Eleventh Circuit Court of Appeals affirmed the District Court’s decision, holding that the ADA’s antidiscrimination provision does not protect a retiree that “neither held nor desired a job with the defendant at the time the discrimination occurred.”  Effectively, the Court of Appeals concluded that an ADA discrimination claim cannot be based solely on post-retirement changes.

The Supreme Court’s Decision

The Supreme Court affirmed the Eleventh Circuit’s ruling in favor of the City. Justice Gorsuch delivered the opinion of the Court, with Justice Jackson dissenting.

Initially, the Court analyzed the statutory text of the ADA, finding that Congress’s choice of present tense verbs made it clear that the ADA’s antidiscrimination provision only applied to current employees or those seeking a position with an employer, not retirees. For example, the Court noted that a “reasonable accommodation” under the Act could include job restructuring or altering training materials—which did not make sense as applied to retirees given they no longer worked for the employer in question or sought a position with the employer. Additionally, the Court highlighted that the retaliation provision of the ADA, as well as the text of Title VII, another federal law prohibiting employment discrimination, used broader terms that were meant to apply to current employees.

The Court ultimately held that, to state a claim of ADA discrimination, the plaintiff must plead and prove that he or she held or desired a job and could perform its essential functions with or without reasonable accommodation at the time of an employer’s alleged act of disability-based discrimination. Therefore, a retired employee would not be able to  bring a disability discrimination claim against a former employer for post-retirement events. The Court noted that if Congress wishes to extend ADA protections to retirees like Stanley, it could do so legislatively, but that the Court was not in a position to create a right not expressed in the statute.

Takeaways

The Stanley decision involves a specific question of law under the ADA. It provides limitations on employment discrimination claims based on disability when the plaintiff is retired. Note, however, that other statutes, both state and federal, may still afford discrimination protections to retirees. Additionally, the court noted that some retirees may still be able to sue for disability discrimination if they can plead and prove that their employer adopted a discriminatory practice while they were still employed (e.g., making them a “qualified individual”).

Please contact your Robbins Schwartz attorney with questions regarding the Supreme Court’s decision or its impact on your employment practices.