06-24-2025
Karyn Stanley worked as a firefighter in Sanford, Florida. At the beginning of her employment, Sanford offered retirees subsidized health insurance until age 65 for those with 25 years of service and those who retired early because of disability. In 2003, Sanford changed its policy and limited health insurance subsidies for those who retired because of disability to 24 months. Stanley retired at 47 in 2018 after she was diagnosed with Parkinson’s disease. The city refused to give her subsidized health insurance until Stanley reached the age of 65. Stanley sued, alleging the city violated the ADA by providing different benefits to 25-year employees compared to disabled employees.
A federal district court dismissed Stanley’s claim, and the circuit court confirmed the dismissal. The U.S. Supreme Court heard the case. Justice Neil Gorsuch wrote the opinion for a court that voted 8-1. The court held that the ADA did not protect Stanley because the alleged discrimination occurred after Stanley retired and left the job. Gorsuch highlighted portions of the ADA that supported this holding. For example, Congress’s use of present-tense verbs in the statute and the kinds of reasonable accommodations suggested all seem to limit the statute to current employees. Gorsuch concluded, “It is hard to see how they might apply to retirees who do not hold or seek a job.” To bring a claim, Stanley had to show that she either held or wanted to hold a job and could perform the “essential functions” of that position with or without accommodation.
Justice Ketanji Brown Jackson wrote the lone dissent. She stated that the court’s decision made the ADA’s provisions meaningless “for disabled workers’ retirement benefits just when those protections matter most.”