Karyn Stanley joined the Sanford, Florida, Fire Department in 1999 and served for nearly two decades. In 2016 she was diagnosed with Parkinson’s disease but continued working for two more years until the progression of her condition forced her to retire on disability in 2018. At the time she was hired, the City provided both service retirees and disability retirees with City-funded health insurance until age 65. In 2003, the City changed that policy, maintaining full coverage for service retirees but limiting that coverage for disability retirees to two years. Stanley, who retired at age 47, learned of the change only after her City-funded coverage ended in 2020.
Stanley sued under the Americans with Disabilities Act, arguing that the City’s decision to offer disability retirees shorter coverage than service retirees was discrimination “in regard to compensation, terms, conditions, and privileges of employment.” The district court dismissed her claim, and the Eleventh Circuit affirmed. Both courts held that Stanley no longer met the ADA’s definition of a “qualified individual” — a threshold requirement for bringing an ADA discrimination claim. Stanley then appealed to the United States Supreme Court, which granted review.
The Supreme Court affirmed. Writing for the majority, Justice Gorsuch explained that Title I of the ADA prohibits discrimination against a “qualified individual with a disability,” meaning a person who “holds” or “desires” a job and “can perform the essential functions of that employment position” with or without reasonable accommodation. Because Stanley had already retired, she did not hold or seek a job, and her alleged injury occurred after her employment ended, she was no longer a “qualified individual” under the statute. The Court reasoned that the statute’s present-tense language and its reference to a remedy of “reasonable accommodations” make clear that Congress intended the ADA to cover only individuals who are part of an ongoing employment relationship, and not retirees.
The Court rejected Stanley’s argument that retirees should remain protected when benefits provided during employment are later reduced because of disability. Title I, the Court explained, protects a certain group of people – “qualified individuals with a disability” – not a certain class of benefits. The Court noted, however, that retirees in similar circumstances may have potential recourse under other statutes, such as the Age Discrimination in Employment Act or the Employee Retirement Income Security Act, but not under the ADA’s employment provisions.
Stanley v. City of Sanford, Fla., 145 S. Ct. 2058 (2025).