Docket 23-997
Stanley v. City of Sanford
DecidedJun 20, 2025
7-2decision
Source: CourtListener.
Court rules retired workers cannot sue under ADA for post-retirement disability discrimination in benefits
Impact6/10
What it does
The Court held that to bring a claim under Title I of the ADA, a person must have held or sought a job — and been able to perform its essential functions — at the time the employer's discriminatory act occurred. Because a retiree who neither holds nor desires a job does not meet that definition of a "qualified individual," she cannot sue under Title I for discrimination that takes place only after she has retired. The ruling resolves a split among federal appeals courts that had divided on this question for years.
Who benefits
Employers — including cities, private companies, and other covered entities — who face fewer ADA discrimination lawsuits from former employees over the terms of retirement benefit plans.
Who is affected
Retired workers with disabilities who believe their former employer is paying them reduced or unequal retirement benefits because of their disability, and who can no longer hold or seek a job at the time the discrimination occurs.
Practical impact
Retired workers with disabilities who are receiving reduced retirement or health insurance benefits compared to non-disabled retirees will generally be unable to bring a Title I ADA claim if they no longer hold or seek employment at the time the discrimination occurs. However, the Court left open a path for workers who can show they were subjected to a discriminatory benefits policy while they were still employed and able to perform their job — meaning the timing of when a discriminatory policy was adopted or applied during employment remains legally significant. Workers may still pursue claims under other federal and state laws, such as the Rehabilitation Act or state anti-discrimination statutes.
Majority — Gorsuch
Joined by: Roberts, Thomas, Alito, Kagan, Kavanaugh, Barrett
The majority held that the ADA's definition of "qualified individual" — someone who "can perform the essential functions of the employment position that such individual holds or desires" — uses present-tense verbs ("holds," "desires," "can perform") that signal the law protects only people who currently hold or seek a job at the time of the alleged discrimination. The Court reasoned that other parts of the statute, such as the definitions of "reasonable accommodation" (job restructuring, modifying facilities for employees) and the examples of discrimination in Section 12112(b) (qualification standards, employment tests), all make sense for current employees or job applicants but not for retirees. The majority also noted that Congress used broader language elsewhere in the ADA — protecting "any individual" from retaliation — which suggests the narrower "qualified individual" language in the employment discrimination provision was intentional. The Court rejected the argument that the ADA's broad purpose of eliminating disability discrimination requires extending Title I to retirees, reasoning that laws do not pursue their goals "at all costs" and that Congress, not the courts, is the proper body to expand the statute's reach. The majority also noted that other laws — including state law and the Rehabilitation Act — may still offer retirees avenues for relief.
Dissent reasoning
In dissent, Justice Jackson argued that the Court should not have used this case to announce a broad rule about post-retirement discrimination at all, because the facts of Lt. Stanley's complaint actually show she was subjected to the discriminatory policy while she was still employed and a "qualified individual" — making the sweeping ruling unnecessary and potentially an advisory opinion untethered to the actual facts. On the merits, the dissent argued that the "qualified individual" definition was never designed to act as a time limit on Title I's protections; rather, Congress inserted it solely to reassure employers that the ADA would not force them to hire or retain workers who cannot do the job. The dissent read the provision as a conditional mandate — if a plaintiff is seeking or holding a job, she must be able to perform its essential functions — but argued it says nothing about when discrimination must occur relative to one's employment. The dissent further argued that retirement benefits are deferred compensation earned during employment, so discriminating against a retiree in the payout of those benefits is, in effect, discriminating against that person in her capacity as a qualified employee who earned them. The dissent warned that the majority's rule produces arbitrary results — an employer who cuts disability-based retirement benefits one day before an employee retires faces liability, but the same employer faces none if it waits one day until after retirement.
Constitutional question
Does Title I of the Americans with Disabilities Act protect a retired employee — who no longer holds or seeks a job — from disability-based discrimination in the payment of retirement benefits?
Precedent changed
The ruling extends and applies Cleveland v. Policy Management Systems Corp., 526 U.S. 795 (1999), which had noted that a plaintiff unable to perform her job may fall outside ADA protections, to the specific context of retirees seeking post-retirement benefits.