Stanley v. City of Sanford raises significant questions about the scope of protections under the Americans with Disabilities Act (ADA) for individuals after employment.

The issue before the Supreme Court is whether a former employee—who was previously qualified for her role and received post-employment benefits during her tenure—loses the right to file a discrimination claim related to those benefits once she is no longer employed.

Karyn Stanley served as a firefighter for the City of Sanford, Florida, for 15 years. She was diagnosed with Parkinson’s disease and continued working for two more years before being unable to perform essential job functions, ultimately retiring in 2018 at the age of 47. Upon her retirement, Stanley, like other employees retiring due to disability, was entitled to employer-paid health insurance to age 65. However, in 2003, the City modified its policy, reducing employer-paid health insurance coverage to 24 months for employees retiring with fewer than 25 years of service.

Stanley sued the City in 2020 after her health insurance benefits expired under the City’s modified policy, claiming that the City’s policy change discriminated against her by not extending coverage until she turned 65. The district court dismissed the case, ruling that Stanley was not a “qualified individual” under the ADA, which defines such individuals as those able to perform core functions of their jobs at the time of employment or those who “hold or desire” to perform the functions of that employment position. The Eleventh Circuit affirmed, concluding that Stanley did not meet the ADA’s criteria because she was no longer employed by the City when her insurance benefits were terminated and had no intention of returning to work for the City. The Supreme Court agreed to hear the case after Stanley argued in her cert petition that the Eleventh Circuit’s decision “acknowledge[d] that the circuits are split,” as even then-Judge Alito recognized two decades ago, this question has long “divided the circuits.”

Stanley’s counsel and the government argued that the alleged discriminatory actions pertained to benefits that Stanley earned while employed as a “qualified individual” under the ADA and, accordingly, ADA protections extend beyond employment to post-employment benefits. In contrast, the City argued that Stanley lacked statutory standing to pursue a discrimination claim because ADA protections apply only to current employees or applicants (who “hold or desire” a job).

During oral argument, the justices questioned both sides about the scope of ADA protections, including whether the ADA extends to “former employees” in any context. Justice Alito suggested whether the case could be decided on a disparate treatment theory, a concept commonly used in ADA cases involving reasonable accommodations. Justice Jackson questioned the relevance of the “qualified individual,” emphasizing that the ADA specifically addresses discrimination in compensation and benefits. Both Justices Kagan and Jackson raised concerns about the implications of allowing retirement benefits claims, noting that individuals would never be eligible to challenge discriminatory treatment if they could not bring claims after they stopped working.

Justices Alito and Kavanaugh explored what other sources of healthcare might be available to Stanley and who should be responsible for providing them. Justices Sotomayor and Kagan inquired whether other anti-discrimination laws might serve as a remedy.

Stay tuned for Dykema’s alert after the Court issues its opinion, which is expected later this term.

For more information, please contact Chantel Febus, James Azadia, Susan Feibus, or Monika Harris.