In Stanley v. City of Sanford, the Court held 7-2 that a retiree is not a "qualified individual" under Title I of the Americans with Disabilities Act of 1990 (ADA), as the statute applies only to current employees or those actively seeking employment.
As previewed in Dykema's February 2025 issue, the case stemmed from a modification to Karyn Stanley's retirement-benefits package. Stanley began working as a firefighter for the City of Sanford, Florida, in 1999. At that time, the City provided health insurance until the age of 65 for those who either (1) retired with 25 years of service, or (2) retired early due to a disability. In 2003, the City revised this policy, offering full insurance benefits only to those with 25 years of service. Individuals retiring early due to disability, like Stanley, were limited to 24 months of health insurance—unless they became eligible for Medicare sooner.
Stanley sued, alleging the City's policy violated the ADA. Specifically, she argued that the disparity in benefits between long-serving retirees and those who retired early due to disability constituted unlawful discrimination.
The legal dispute before the Supreme Court centered on the interpretation of 42 U.S.C. § 12112(a). Both parties agreed that retirement benefits constitute "compensation" and that the policy change implicated disability-based distinctions. However, they disagreed on whether Stanley, as a retiree, qualified to sue under Title I of the ADA. Stanley argued that because she was not seeking or holding a job, she was not required to meet the statute's definition of a "qualified individual." The Court rejected that argument, reasoning that adopting such a view would expand Title I protection to all retirees, contrary to the statutory framework.
Stanley also argued that excluding retirees rendered language in § 12111(8) and § 12112(b)(5)(A) surplusage, as the latter already includes in its definition "an otherwise qualified individual with a disability who is an applicant or employee." She urged the Court to interpret Title I more broadly to encompass any individual affected by alleged discrimination, even if not currently employed or seeking work. The Court declined, holding that Title I's protections are limited to employment-reared contexts. Writing for the majority, Justice Gorsuch emphasized that interpreting the statute as written falls to the Court, while expanding its scope lies within Congress's purview.
The Court did not leave Stanley without recourse. The Court noted that Stanley may have had an alternative remedy. In a rare move, the majority addressed a secondary issue raised in briefing: whether Stanley might have stated a valid claim under 42 U.S.C. § 2000e-5(e)(3)(A), which covers compensation-related discrimination. But because Stanley failed to allege when her disability arose or whether she worked while disabled, the Court declined to reach that issue on the merits.
Justice Thomas, joined by Justice Barrett, concurred in part and wrote separately to caution against the growing trend of parties seeking certiorari on one issue but arguing another. He emphasized the importance of issue preservation, stating that the Court should not address unpreserved questions absent extraordinary circumstances—which he found lacking in this case.
Justice Jackson, joined by Justice Sotomayor, dissented. The dissent criticized the majority's rigid textualism, arguing that the ADA's protections extend beyond active employment to include benefits flowing from the employment relationship. Justice Jackson contended that "qualified individual" should be interpreted contextually: a person must show qualification only when seeking to obtain or retain employment. She argued that the majority imposed an unwarranted temporal limitation and failed to recognize the ADA's broader remedial purpose.
Takeaways
- Retirees are not "qualified individuals" under Title I of the ADA and therefore cannot bring employment discrimination claims under that provision unless they hold or seek employment.
- To bring a successful Title I claim, a plaintiff must demonstrate they were employed or actively pursuing employment at the time of the alleged discriminatory act.
- Alternative legal pathways may exist for retirees alleging benefit-based discrimination, including claims under § 2000e-5(e)(3)(A), which addresses discriminatory compensation practices.
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