The United States Supreme Court (SCOTUS) decision in Stanley v. City of Sanford, Florida, issued June 20, 2025, reminded us about some of the fundamentals of the Americans with Disabilities Act (ADA), and what it takes to qualify for its protections.
In 1999 Ms. Stanley started working as a firefighter for the City of Sanford, Florida (the "City"). A deciding factor for her in going to work at the City was that it had good health insurance. In fact, at the time she started, the city offered retiree health insurance, until age 65, for two categories of retirees: those who retired with 25 years of service, and those who retired earlier because of a disability. In 2003 the City changed its policy. While the City said they would pay retiree health insurance for retirees with 25 years of service to age 65, it would not pay more than 24 months of health insurance for employees who had less than 25 years of service and who retired due to disability. Unfortunately for Ms. Stanley, she was forced to retire before reaching 25 years of service due to a disability – which meant she was entitled to no more than 24 months of health insurance.
Ms. Stanley filed suit against the City alleging disability discrimination regarding the amount of benefits she received under the City's policy due to her disability. Her first legal hurdle to overcome in the case was to prove that she was in fact a "qualified individual" under the ADA.
The ADA defines a "qualified individual" as "an individual who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires." In the Stanley decision, SCOTUS narrowed the issue down to whether a retired employee, who does not currently hold or is otherwise seeking a job, can be a "qualified individual."
When the Stanley case was heard, there was a split between the circuit courts of appeal regarding whether a retiree could be a covered "qualified individual" under the ADA. SCOTUS took up the Stanley case to resolve the circuit courts' disagreement. Put simply, SCOTUS analyzed whether an individual who is not trying to get or keep a job is nonetheless still entitled to ADA protections, and if they are protected, does the ADA's "reasonable accommodation" process include mandating receipt of health insurance benefits?
In reaching its decision, SCOTUS observed that in order for an employee to be a "qualified individual" under the ADA, the employee must be ready, willing, and able to work. If thee employee does not fall into that category, then they are not covered by the ADA. SCOTUS ruled that Stanley was not willing and able to work, thus she was not covered by the ADA.
The Stanley decision also touches on the question of whether discrimination against disabled persons applies to the receipt of fringe benefits like health insurance benefits. Guidance from the Equal Employment Opportunity Commission has stated for many years that:
The ADA prohibits discrimination in all employment practices, including ... compensation, training, and other terms, conditions, and privileges of employment. It applies to ... fringe benefits, and all other employment-related activities.
In Stanley, SCOTUS confirmed that health benefits for disabled employees is a protected benefit, but not for retired employees. Rather, health insurance is a benefit which a qualified employee would be entitled to receive in conjunction with their ADA rights.
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