The U.S. Supreme Court affirmed the decision of the Court of Appeals for the Eleventh Circuit, which held that retired employees are not “qualified individuals” under Title I of the Americans with Disabilities Act (ADA), and therefore are not entitled to sue their former employer for post-employment benefits. Ninth Circuit precedent was already aligned with this U.S. Supreme Court decision.
The plaintiff was Karyn Stanley, a firefighter who was diagnosed with Parkinson’s disease. In 2018, Stanley retired after her disease left her incapable of performing essential job duties. After retiring, Stanley learned that in 2003, the City changed its policy to only provide retirement benefits to disabled retirees for 24 months following their retirement. Stanley sued in 2020.
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.
The Eleventh Circuit Court of Appeals held 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 U.S. Supreme Court affirmed, 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.
Stanley v. City of Sanford, 145 S.Ct. 2058 (2025).