Stanley V City Of Sanford

Karyn Stanley worked as a firefighter for Sanford, Florida, from 1999. In 2003, the city revised its health insurance policy to provide coverage until age 65 for retirees with 25 years of service but only 24 months for those retiring due to disability. Stanley retired in 2018 due to Parkinson's disease and was entitled to 24 months of coverage. She sued under the ADA, arguing the policy discriminated against disabled retirees. The district court and Eleventh Circuit dismissed her claim, stating she was not a 'qualified individual' under the ADA after retirement. The Supreme Court affirmed, holding that the ADA's protections apply only to individuals who hold or desire a job at the time of discrimination.

The primary issue was whether the Americans with Disabilities Act (ADA) protects retirees who no longer hold or desire a job from disability-based discrimination in the provision of retirement benefits. The Supreme Court affirmed the Eleventh Circuit’s holding that Title I of the ADA does not extend to retirees in such circumstances, resolving a circuit split and emphasizing textual limits in the statute.

The judgment is affirmed, upholding the Eleventh Circuit's decision that the Americans with Disabilities Act does not protect retirees who neither hold nor desire a job at the time of discrimination.

The Supreme Court affirmed the Eleventh Circuit's judgment dismissing Karyn Stanley's Americans with Disabilities Act (ADA) claim, holding that retirees who neither hold nor desire a job at the time of discrimination are not protected under §12112(a) of the ADA. The Court concluded Stanley was not a 'qualified individual' when the alleged discrimination occurred after her retirement.

The Supreme Court held that Title I of the Americans with Disabilities Act (ADA) does not protect retirees who neither hold nor desire a job at the time of discrimination. The Court emphasized the literal interpretation of the statutory text, particularly the present-tense verbs in the definition of 'qualified individual' (42 U.S.C. §12111(8)), which require a plaintiff to be someone who can perform the essential functions of a job they hold or seek at the time of the alleged discrimination. This textual analysis led to the conclusion that retirees are not covered under the ADA's anti-discrimination provisions for post-employment benefits.