On June 20, 2025, the Supreme Court of the United States of America issued an Opinion in Stanley v. City of Sanford, Florida, 606 U.S. ___ (2025). The matter was on appeal from the Eleventh Circuit Court of Appeals. Karyn Stanley worked as a firefighter for the City of Sanford, Florida from 1999 through 2018 when she retired due to a disability.
When Stanley was hired, the City offered health insurance until age 65 for two categories of retirees: those who retired with 25 years of service and those who retired early because of a disability. In 2003, the City changed its policy to state that going forward, it would continue to pay for health insurance up to age 65 for retirees with 25 years of service. The policy was changed to state that if employees retired earlier due to disability without 25 years of service, it would now provide health insurance for only 24 months after disability retirement, unless the retiree started receiving Medicare benefits sooner.
Under the policy at the time of Stanley’s disability retirement, Stanley was entitled to, at most, 24 months of health insurance. Stanley sued the City after her retirement and argued that the policy’s differentiation between years of service and disability for health insurance benefits violated the Americans with Disabilities Act (“ADA”) and other state and federal laws. The District Court granted the City’s Motion to Dismiss Stanley’s Complaint as to Stanley’s ADA discrimination claim because the alleged discrimination did not come until after she retired and she was no longer a “qualified individual” under the ADA. The District Court denied the Motion to Dismiss as to Stanley’s other stated and federal claims. The Eleventh Circuit affirmed the dismissal of Stanley’s ADA claim.
The Supreme Court granted certiorari for Stanley’s ADA claim because there was a dispute amongst the Circuit Courts of Appeal regarding whether a retiree is a qualified individual under the ADA. The Eleventh, Six, Seventh, and Ninth Circuits had held that retirees were not qualified individuals under the ADA. The Second and Third Circuits had held that retirees were qualified individuals under the ADA.
The Supreme Court stated that Stanley’s claim was made under Title I of the ADA, which applies to employment. Title I makes it “unlawful for a covered employer to ‘discriminate against a qualified individual on the basis of disability in regard to…compensation,’ among other things.” The Court stated that the claim is focused upon whether a retiree is a “qualified individual” under Title I. A qualified individual is defined as someone “who, with or without reasonable accommodation, can perform the essential functions of the employment position that [she] holds or desires.” Section 12112(8) of Title I of the ADA.
The Court looked to the verb tense within the statute, noting that the qualified individual definition contains present tense verbs. It also noted that the majority of the language in Title I applies to prospective and current employees, without any mention of retirees. The Court could not find any basis in the language of Title I or its precedent to support the expansion of qualified individual to include retirees under the ADA. The Court ultimately held that Stanley’s ADA claim cannot proceed because she is not a qualified individual because she did not bring her claim until she was a retiree.
The Court then went on to explain that there could foreseeably be circumstances where a policy providing for different retirement benefits based upon a disability could still violate the ADA. The Court focused on the fact that Stanley was a retiree when she made her claim. The Court noted that if Stanley had been disabled and employed when the policy change was implemented in 2003, she could potentially have had an ADA claim if she was affected by the policy.
The Court clarified that this ruling does not completely bar Stanley from recovery for discriminatory treatment. The Court noted that Stanley’s claims under the Rehabilitation Act and the Equal Protection Clause of the Fourteenth Amendment were permitted to proceed at the District Court level. Similarly, state laws prohibiting discrimination against disabilities could provide the basis for a claim.
Practically, this case does not mean employers are immune from suit for changing a health insurance policy that only affects disability retirements or resignations. Employers should still evaluate changes to post-retirement benefits to ensure that different groups of people are not being treated differently based upon a protected characteristic.
Takeaways:
- The Supreme Court held that a retiree cannot sue under Title I of the Americans with Disabilities Act for a policy change that reduced health care insurance benefits for employees that retired before 25 years of service due to a disability.
- Current or prospective employees can sue under Title I of the ADA for a policy change that discriminated against disabled employees for retirement benefits.
- Prospective and current employees and retirees can sue under the Rehabilitation Act, Equal Protection Clause of the Fourteenth Amendment, or other state or federal claims if a policy discriminatorily impacts post-retirement benefits based upon a disability.
- Employers must continue to ensure that post-retirement benefit policies do not discriminate against disabled prospective, current, or retired employees.
The Bottom Line:
The Supreme Court held that a retiree is not a “qualified individual” under Title I of the Americans with Disabilities Act. This ruling prohibited Stanley from bringing a claim that the City’s policy limiting post-retirement health insurance for disability retirements before 25 years of service violated the ADA. The Supreme Court cautioned though that a post-retirement benefit policy discriminating against prospective or current employees based upon disability could still violate the ADA, Rehabilitation Act, or Equal Protection Clause of the Fourteenth Amendment, among other state and federal laws.
