The Americans with Disabilities Act (ADA) imposes a general requirement on employers with fifteen or more employees to refrain from discriminating against qualified individuals on the basis of a disability. For those covered employers, the ADA is most familiar for its requirement that employers make ‘reasonable accommodations’ to workers with a disability when such an accommodation is necessary to enable an individual to perform his or her job. In a recent decision, the U.S. Supreme Court addressed the scope of the protections offered by the ADA to a retiree challenging the application of a policy that restricted available retirement benefits.
In Stanley v. City of Sanford, Florida, the Court confronted a claim asserted by a firefighter who retired due to a disability more than a year prior to filing her lawsuit. At the heart of her claim was a city policy that permitted employees who retired with 25 years of service to receive health benefits until the age of 65, while, at the same time, limiting health benefits for individuals who retired as a result of a disability to a period of only 2 years following their retirement date.
In deciding the case in favor of the city, the Court concluded that, because the plaintiff was no longer employed or seeking employment at the time her claim was filed, she was outside the scope of individuals entitled to pursue a claim under the ADA. The Court specifically noted that the ADA prohibits discrimination against a “qualified individual,” which the statute defines as an individual “who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires.” Based on that language, the Court concluded that the ADA’s protections only extend to an individual who, as of the time of the alleged discrimination, either holds or desires a job with the employer. In doing so, the Court rejected the notion that the ADA must necessarily apply due to the fact that the claim related to benefits that flowed from a prior employment relationship, with the Court noting that “the statute protects people, not benefits, from discrimination.”
Since the plaintiff was retired as of the time she filed her claim (and was therefore not a “qualified individual” currently holding or seeking a job with the city), the Court held that she could not meet the requirements to maintain a claim under the ADA. The Court’s opinion did note the possibility of claims under other statutes on which to challenge the alleged disparities in benefits following retirement. The ADA, however, was found to provide no relief.
