The U.S. Supreme Court heard oral arguments on Jan. 13, 2025, in Stanley v. City of Sanford (No. 23-997), which addresses whether former employees have a right to sue their former employer under the Americans with Disabilities Act (ADA) for discrimination relating to receipt of post-employment fringe benefits.
Factual Background
Karyn Sanford is a former firefighter for the City of Sanford, Florida. In 2016, Sanford was diagnosed with Parkinson’s disease. Two years later, in 2018, she retired from the fire department as a result of her condition. During her employment with the City, the City’s benefit policy provided a health insurance subsidy to employees until the age of 65 who had retired after 25 years of service or because of a disability. In 2003, the City’s policy was amended to provide this subsidy until the age of 65 only to employees who retire after 25 years of service. The policy was further changed to provide the subsidy to those who retire as a result of disability for a period of only 24 months or until they became eligible for Medicare. As a result, Stanley ceased to receive this subsidy beginning in 2020.
In April 2020, Stanley filed suit against the City alleging the City discriminated against disabled retirees in its administration of these retirement benefits in violation of the ADA. It is the City’s position that former employees, including Ms. Stanley, lack standing to bring discrimination claims under, among others, the ADA for post-retirement fringe benefits.
Procedural History
The U.S. District Court for the Middle District of Florida dismissed Stanley’s complaint, holding that the alleged discrimination relating to cessation of the health insurance subsidy payments occurred after Stanley was employed by the City, thus Stanley was not a “qualified individual” covered by the ADA. The Eleventh Circuit Court of Appeals affirmed the lower court’s decision, finding Stanley was not a “qualified individual” under the ADA as she was not employed by the City when her benefits were terminated, nor did she desire such employment.
Arguments
Before the Court, Stanley’s counsel and the Solicitor General’s office argued the alleged discriminatory actions related to benefits that Stanley earned while employed as a “qualified individual” under the ADA, thus the protections of the ADA extend beyond a period of active employment, including as it relates to post-retirement fringe benefits.
On the other hand, the City’s counsel argued that Stanley could not establish the City discriminated against her as the ADA protections extend only to current employees or applicants, and thus Stanley lacked standing to pursue her ADA claim. Counsel further argued that extending these protections to “unqualified individuals” would impose an undue burden on employers and an influx of litigation relating to post-employment benefits.
Court’s Inquiries
During the argument, the justices peppered both sides with various questions concerning the scope of ADA protections, including whether “former employees” are not afforded such protections in any context. Additionally, Justice Samuel Alito questioned Stanley’s counsel on the complex issues that would be presented to courts in analyzing whether the distinction between an individual who works for 25 years and somebody who works a shorter period of time and retired based on a disability is unlawful. Finally, the justices raised questions concerning the possible impact a decision in Stanley’s favor could have with respect to administration of benefits.
Potential Impact
The decision in this matter, expected this summer, could have significant and wide-ranging consequences for employers around the country. The decision will likely provide guidance to employers as to the limits on ADA protections, especially as it relates to the administration of post-employment fringe benefits.