By: Dan Burke and Briana Blair*
In Stanley v. City of Sanford (June 20, 2025), the United States Supreme Court considered whether the Americans with Disabilities Act (ADA) protects former employees against disability discrimination with respect to retirement benefits distributed after employment ends.
Karyn Stanley served as a firefighter in Sanford, Florida for almost 20 years. Stanley was diagnosed with Parkinson’s disease in 2016. She retired from her role as a fire lieutenant in 2018 due to the progress of her disease. Once retired, she discovered the benefits plan had changed years before. The change reduced benefits available to disabled retirees. While traditional retirees receive a health insurance subsidy until the age of 65, disabled retirees would only be covered for two years.
Stanley brought suit against the city in 2020, nearly two years into her retirement. She argued that the change made to the benefits policy unlawfully discriminated against those with career-ending disabilities, in violation of the ADA.
A federal district court, along with the U.S. Court of Appeals for the Eleventh Circuit, dismissed her claim. Stanley then appealed to the Supreme Court, which agreed to review her case to resolve a split in the federal courts.
The Supreme Court upheld the dismissal of Stanley’s claim, ruling that the language of the ADA – specifically the term “qualified individual” – is limited to include only those who experience actionable discrimination while they are capable of performing the essential duties of the job they hold or seek.
This decision clarifies who is protected by the ADA and can therefore bring discrimination claims under the ADA.
This decision presents a couple of key takeaways for employers:
- Definition of “Qualified Individual”
The ADA defines a “qualified individual” as someone who, with or without reasonable accommodation, can perform the essential functions of the job they hold or desire.
The Court highlighted the use of present-tense language– “holds,” “desires,” “can perform”—to determine that former employees who are not seeking reemployment are not covered by the ADA.
- Scope of the ADA
The ADA applies to employment-related discrimination, not post-employment benefits, unless the individual is still a “qualified individual.”
This decision is a timely reminder that determining whether an individual is protected by the ADA can be a challenging question to resolve.
Bricker Graydon’s Labor and Employment Group stands ready to assist your company in any ADA or employment matters.
*Briana Blair is a Law Clerk and not licensed to practice law.