Employment Law Report
Supreme Court Narrows ADA Protections for Retirees in Stanley v. City of Sanford
Written by: Lillie Stivers
Recently, the U.S. Supreme Court ruled in Stanley v. City of Sanford, Florida that the Americans with Disabilities Act (ADA) did not protect retirees from post-employment benefit discrimination under Title I of the statute.
The Case at a Glance
Karyn Stanley, a firefighter for the City of Sanford since 1999, retired in 2018 at age 47 after being diagnosed with Parkinson’s disease. At the time of her hiring, the City offered health insurance coverage until age 65 for employees who retired due to disability. However, a 2003 policy change limited that coverage to just 24 months for disabled retirees, while those with 25 years of service retained coverage until age 65.
Stanley sued under the ADA, arguing that the City’s policy discriminated against her based on her disability. Lower courts dismissed her claim, and the Supreme Court affirmed those decisions in a 7–2 ruling.
The Court’s Reasoning
Writing for the majority, Justice Neil Gorsuch emphasized that Title I of the ADA protected only “qualified individuals”—defined as those who “hold or desire” a job and can perform its essential functions. Because Stanley was retired and no longer held or desired a position, the Court held that she did not meet this definition.
Gorsuch wrote, “The statute protects people, not benefits, from discrimination,” underscoring that the ADA’s employment protections did not extend to post-employment benefits for former workers.
What This Means for Employers and Employees
This decision narrows the scope of ADA protections and gives employers greater leeway in structuring retiree benefits so long as those changes don’t violate other laws like the Employee Retirement Income Security Act (ERISA). The ruling underscores the importance of reviewing benefit policies to ensure compliance with applicable statutes beyond the ADA.
While the Court left open the possibility that other legal avenues might protect retirees from discrimination, the burden now shifts to Congress if broader protections are to be reinstated. In the meantime, employers should tread carefully when modifying post-employment benefits, especially for workers who retire due to disability.
