Supreme Court Holds That Retired Employees Cannot Sue For Post-Employment Benefits Under The ADA

Client Alert  |  June 20, 2025


Stanley v. City of Sanford, Fla., No. 23-997 – Decided June 20, 2025

Today, the Supreme Court held 7-2 that the Americans with Disabilities Act does not extend to retired employees.

“[T]o prevail under [Title I of the ADA], a plaintiff must plead and prove that she held or desired a job, and could perform its essential functions with or without reasonable accommodation, at the time of an employer’s alleged act of disability-based discrimination.”

Justice Gorsuch, writing for the Court

Background:

The Sanford Fire Department previously provided health insurance until age 65 for two categories of retirees:  (1) those who retired with 25 years of service and (2) those who retired earlier because of a disability.  In 2003, Sanford reduced the insurance period for those who retired due to disability to 24 months following retirement.

Karyn Stanley started working as a Sanford firefighter in 1999.  She retired due to disability in 2018.  Under Sanford’s revised policy, she was only entitled to 24 months of post-retirement health-insurance coverage.  In 2020, Stanley sued Sanford, alleging that providing different benefits to those who retired with 25 years of service and those who retired earlier due to disability was impermissible discrimination under Title I of the Americans with Disabilities Act.

The district court dismissed the suit, holding that Stanley was not a “qualified individual” under the ADA because she was retired.  She was not able to perform the essential functions of a job she held or desired at the time the City ceased providing her health insurance.  The Eleventh Circuit agreed, but acknowledged a split among the circuits as to whether the ADA reached retirees like Stanley.

Issue:

Under the Americans with Disabilities Act, does a former employee—who was qualified to perform her job and who earned post-employment benefits while employed—lose her right to sue over discrimination with respect to those benefits solely because she no longer holds her job?

Court’s Holding:

Yes.  Title I’s anti-discrimination provision does not protect individuals who do not hold nor desire a job with the defendant employer at the time of the allegedly discriminatory act.

What It Means:

  • Today’s decision clarifies that the ADA does not cover retired employees who neither hold nor desire a job at the time of the allegedly discriminatory conduct.  But because retired employees might have other avenues by which to challenge changes to retirement-benefit plans, employers should continue to exercise caution in making such changes.
  • A plurality of the Justices (Gorsuch, joined by Alito, Sotomayor, and Kagan) wrote separately to opine that, unlike retired employees, employees who were both disabled and “qualified” when their employer adopted a discriminatory retirement-benefits policy might be able to state a claim under Title I.  Justice Jackson articulated a similar view in her dissent.

The Court’s opinion is available here.

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This alert was prepared by Cate McCaffrey and Elizabeth Strassner.

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