In, 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...
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