Supreme Court Rules ADA Does Not Extend to Retirees

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On June 20, 2025, the Supreme Court of the United States (the “Supreme Court”) issued a decision in Stanley v. City of Sanford, Florida, holding that the Americans with Disabilities Act (“ADA”) does not extend to discrimination claims from retired employees who are no longer working or seeking employment. 

Background

Karyn Stanley (“Stanley”) served as a firefighter for the City of Sanford, Florida (the “City”) for nearly two decades before retiring due to a disability in 2018. At the time of her hiring in 1999, the City’s policy was to provide health insurance until age 65 for two categories of retirees: (1) those with 25 years of service, and (2) those who retired earlier due to disability. In 2003, however, the City amended its policy to limit retiree health coverage to only those with 25 years of service. Under the new policy, any retirees who retired early due to disability would only be eligible for 24 months of health coverage. Unaware of this change, Stanley retired due to disability and received just 24 months of coverage.

Stanley sued, arguing that the City’s policy discriminated against her based on her disability by providing less generous benefits than those offered to retirees who retire with 25 years of service. The district court dismissed her claim, holding that she was not a “qualified individual” under the ADA because she no longer held or sought employment with the City. The Eleventh Circuit affirmed the ruling.

Decision

The Supreme Court affirmed the lower courts’ decisions, holding that the ADA does not extend to former employees who are no longer employed and are not seeking employment at the time of an employer’s alleged act of discrimination.

Under Title I of the ADA, employers are prohibited from “discriminat[ing] against a qualified individual on the basis of disability” in matters such as compensation and benefits. The statute defines a “qualified individual” as someone “who, with or without reasonable accommodation, can perform the essential functions of the employment position that [she] holds or desires.”

 The Supreme Court emphasized that the pertinent question here concerned whether a retired employee who does not hold or seek a job is a “qualified individual.” The Supreme Court then reasoned that the ADA’s protections are limited to individuals who currently hold or seek a job. Since Stanley had already retired when the alleged discrimination occurred (the reduced healthcare benefits), she did not meet this definition under the ADA.

The Supreme Court pointed to the use of present-tense verbs in the ADA definition —“holds,” “desires,” and “can perform”—to support its conclusion that the law protects individuals able to perform a job they currently hold or seek when discrimination occurs, not retirees who neither hold nor desire employment. Accordingly, these protections do not extend to retirees, who neither hold a position nor intend to return to the workforce. The Supreme Court also noted that if Congress intended to extend ADA protections to retirees, it could amend the statute to do so.

Key Takeaways for Employers

The decision highlights the fact that employers may treat retired employees differently without violating the ADA, provided the individuals are no longer working or seeking employment. Furthermore, the decision provides employers with greater flexibility in structuring retiree benefits, offering employers more latitude in plan design.

Although this decision narrows the scope of ADA protections, employers must still comply with other federal and state laws, including the Employment Retirement Income Security Act of 1974 (“ERISA”). As such, legal counsel should be consulted before making any changes to retiree benefit programs.