Last week in a 7-2 decision, the U.S. Supreme Court held that Title I of the Americans with Disabilities Act does not apply to claims by a former employee that changes to her retiree medical benefits discriminated against her based on her disability. In Stanley v. City of Sanford, the plaintiff was a firefighter forced to retire due to Parkinson’s disease. Following her retirement, she sued the city, alleging that changes to its retiree medical plan discriminated against employees who left the workforce due to a disability.
The Eleventh Circuit Court of Appeals held that the ADA’s prohibitions against employment discrimination only apply to active and not former employees. The Supreme Court agreed, affirming dismissal of the lawsuit. The majority opinion noted that the ADA’s key definition of a protected disabled individual covers someone who is capable of performing the essential functions of the job, with or without reasonable accommodation. By definition, a disabled retired employee is incapable of performing those job functions, placing them outside the plain language of Title I’s protections.
The Supreme Court noted that the plaintiff could have challenged the city’s benefit plan between the time she was diagnosed with her medical condition and her retirement date. This decision resolves a split among the federal appellate circuits. It closes the door on the ability of retired employees to allege employment discrimination under the ADA. While the statute’s protections apply to employee benefits provided to active workers, former employees upset about changes to post-retirement benefits will need to devise other ways to challenge the legality of such decisions.
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