On June 20, 2025, the U.S. Supreme Court, in Stanley v. City of Sanford, 606 U.S. ____ (2025), affirmed the decision of the Court of Appeal for the Eleventh Circuit which held that retired employees are not “qualified individuals” under Title I of the American with Disabilities Act (“ADA”), and therefore are not entitled to sue their former employer for post-employment benefits.
The ADA prohibits employers from adopting and implementing policies or practices that discriminate against “qualified individuals” based on the individual’s disability. Title I of the ADA defines a “qualified individual” to mean someone with a disability who, with or without reasonable accommodation, can perform the essential functions of the job that they hold or desire.
This case addressed three points involving the ADA. First, whether retirement benefits distributed after employment ends are protected under Title I’s provisions against discrimination in “employee compensation.” Second, whether post-employment discrimination related to fringe benefits is actionable. In other words, does a former employee have standing to sue their employer even though they are no longer employed? Third, whether a retiree, who is unable to perform essential job duties can “hold or desire” a position with their former employer such that they are “qualified individual” able to sue under the ADA.
Plaintiff, Karyn Stanley, worked as a firefighter for the City before being diagnosed with Parkinson’s disease in 2016. Two years later, in 2018, Stanley was forced to retire from the City after her disease and accompanying disabilities left her incapable of performing essential job duties. After retiring, Stanley discovered that in 2003 the City had changed the retirement benefits to which she was entitled. Previously, the City provided all employees with healthcare benefits until they reached the age of 65. In 2003, the City changed its policy to only provide retirement benefits to disabled retirees for 24 months following their retirement.
The District Court dismissed Stanley’s claims under the ADA, reasoning that Stanley could not state a plausible disability discrimination claim because the alleged discriminatory act occurred after Stanley was no longer an employee.
The Court of Appeal considered three points at which Stanley could potentially have brought her claim against the City: (1) in 2003, when the City amended its policy concerning health insurance contributions; (2) in 2016, following her Parkinson’s Diagnosis; or (3) in 2020 when the change in policy affected Stanley as a former City employee. The Court of Appeal considered each of these times before holding that Stanley could not sue in 2020 because, at that point, she was retired from the City and therefore not a “qualified individual” under the ADA.
The Court of Appeal held that, under ADA’s anti-discrimination provision, “a plaintiff’s claim must depend on an act committed by the defendant while the plaintiff was either working for the defendant or seeking to work for the defendant.” (Stanley v. City of Sanford 83 F.4th 1333, 1339.) The Court of Appeal held that Stanley lacked standing to sue the City in 2020 because she was not a “qualified individual” at the time of the suit.
The Supreme Court affirmed the Court of Appeal, holding that Stanley was not a “qualified individual” under the ADA when she filed suit because she was neither a qualified applicant for employment nor a current employee at the time of the alleged discrimination.
Prior to the Supreme Court’s decision in this case, the Ninth Circuit Court of Appeals, the court with appellate jurisdiction in California, held that former employees are not “qualified individuals” under the ADA. Thus, California employers are not subject to any changes to applicable law because of the decision in this case.
Liebert Cassidy Whitmore attorneys are closely monitoring developments in relations to this Special Bulletin and are able to advise on the impact this could have on your organization. If you have any questions about this issue, please contact our Los Angeles, San Francisco, Fresno, San Diego, or Sacramento office.