On June 20, 2025, the United States Supreme Court issued an important ruling in Stanley v. City of Sanford, Florida, which significantly narrows the scope of the protections under Title I of the Americans with Disabilities Act (“ADA”). The Court held that retirees are not “qualified individuals” under the ADA, and therefore may not sue their former employers for disability-related discrimination stemming from changes in post-employment benefits.
The case involved a former Stanford, Florida firefighter who retired early at the age of 47 after being diagnosed with Parkinson’s Disease. After she retired, the City of Stanford decided to cut health insurance subsidies for disabled retirees with less than 25 years of service to just 24 months. Retirees with 25 or more years of service enjoyed the health insurance benefits until age 65. The Plaintiff who is completely disabled and retired with less than 25 years of service sued the City of Stanford asserting that the City of Stanford’s policy violated the ADA.
The majority of the Supreme Court focused on the plain language of the ADA in finding that the statute defines “qualified individual” as someone who “holds or desires a job and can perform its essential functions. The Court affirmed the trial court’s dismissal of Ms. Stanley’s discrimination suit because she was retired and no longer capable of working. The Court reasoned that Ms. Stanley could not pursue a claim under Title I of the ADA because she did not hold or desire a job and could not perform the job’s essential functions because of her retirement due to her disability.
The Court did, however, leave open a potential narrow path for retirees who could show that they were disabled and qualified when the alleged discriminatory policy was adopted. The Court held that Ms. Stanley could not make that showing because she was already retired and out on disability when the policy was changed.
The decision gives employers more certainty when modifying or discontinuing retiree benefits, so long as changes to those benefits do not violate another federal or state statute like, the Employment Retirement Income Security Act of 1974 (“ERISA”).
This important decision finds that retirees cannot assert ADA claims solely based on post-retirement changes. The decision could be overturned if Congress decides to expand the plain language in Title I of the ADA to bestow rights to retired people. That seems unlikely at this time.
