Stanley v. City of Sanford, Florida
In brief
A retired former employee cannot bring this ADA claim for alleged discrimination in post-retirement benefits unless she held or sought a job when the alleged discrimination occurred.
- Where it stands
- Decided
Decided 8-1 · June 20, 2025 · Opinion by Justice Gorsuch
- What it’s about
- This case addressed whether a retired firefighter could sue her former employer under the Americans with Disabilities Act (ADA) for reducing her post-retirement health benefits.
- Who it affects
- Retirees generally cannot use this ADA provision to challenge disability-based changes to benefits after they leave work.
Summary: written with AI from the case record.
What it's about
The Supreme Court ruled that the ADA's protections apply only to individuals who currently hold or desire a job, not to former employees who have already retired.
The case defines who counts as a protected qualified individual under the ADA's employment-discrimination provision.
Question presented
Under the Americans with Disabilities Act, does a former employee-who was qualified to perform her job and who earned post-employment benefits while employed-lose her right to sue over discrimination with respect to those benefits solely because she no longer holds her job?
What the Court decided
Holding
The judgment is affirmed. 83 F. 4th 1333, affirmed. JUSTICE GORSUCH delivered the opinion of the Court with respect to Parts I and II, concluding that, to prevail under §12112(a), a plaintiff must plead and prove that she held or desired a job, and could perform its essential functions with or without reasonable accommodation, at the time of an employer’s alleged act of disability-based discrimination.
- Result
- Affirmed
The vote
- Joined the judgment
- Concurred in a separate opinion
- Dissented
- Wrote an opinion
- Concurring · 2agreed with the result, wrote separately
- Dissenting · 1disagreed with the result
- Jacksonwrote the dissent
From the opinions
“to prevail under §12112(a), a plaintiff must plead and prove that she held or desired a job, and could perform its essential functions with or without reasonable accommodation, at the time of an employer’s alleged act of disability-based discrimination.”
“As I understand today’s holding, the Court has decided that if a worker who has earned retirement benefits leaves the workforce (as expected) and is then discriminated against with respect to the provision of those earned benefits because she is disabled, Title I offers no protection.”
What's next
The decision remains binding for lower courts deciding ADA employment-discrimination claims. Employers, retirees, and agencies must assess whether an employee held or sought a job when the alleged discriminatory action occurred.
Why it matters
For example, a retired worker challenging reduced health benefits must show the alleged discrimination occurred while the worker held or sought a job.
Documents
Docket activity
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
New analysis added
AI analysis generated: Case Briefing
Show 7 moreShow fewer
AI analysis generated: Decision Record
Status changed from unknown to unknown
Status changed from unknown to unknown
Opinion added: opinion
Opinion added: Stanley
Audio Recording added: Oral Arguments - Stanley
Status changed from unknown to unknown
More questions
- What did the Supreme Court rule in Stanley v. City of Sanford?
- The Court said an ADA plaintiff must hold or seek a job when the alleged disability discrimination occurs. It affirmed the Eleventh Circuit.
- Who won Stanley v. City of Sanford?
- The City of Sanford won. The Court ruled 8-1 against retired firefighter Karyn Stanley's ADA claim.
- What does Stanley v. City of Sanford mean for retired workers?
- Retired workers generally cannot bring this ADA claim over discrimination in benefits occurring after retirement. The worker must have held or sought a job then.
- Is the ADA rule still the law after Stanley v. City of Sanford?
- Yes. Lower courts must apply the Court's rule that a plaintiff must hold or seek a job at the time of alleged discrimination.
- What happens next after Stanley v. City of Sanford?
- Lower courts will apply the decision in ADA employment cases. Employers and affected workers will evaluate when the alleged discrimination occurred.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.