Karyn Stanley worked as a firefighter for the City of Sanford, Florida, starting in 1999. At first, she planned to serve for 25 years. Part of the reason for that had to do with health insurance. When Ms. Stanley was hired, the City offered health insurance until age 65 for two categories of retirees: those with 25 years of service and those who retired earlier due to disability.

In 2003, the City changed its policy to provide health insurance up to age 65 only for retirees with 25 years of service, while those who retired earlier due to disability would receive just 24 months of coverage.

Ms. Stanley later developed Parkinson’s disease, a disability that forced her to retire in 2018, entitling her to only 24 months of health insurance under the revised policy.

Ms. Stanley sued, claiming the City violated the Americans with Disabilities Act by providing different health-insurance benefits to those who retire with 25 years of service and those who retire due to disability.

The City responded by filing a motion to dismiss Ms. Stanley’s complaint for failure to state a claim. The district court denied that motion in part, allowing some of Ms. Stanley’s claims to proceed. But with respect to her ADA claim, The district court dismissed her ADA claim, reasoning that the alleged discrimination occurred after she retired, when she was not a “qualified individual” under Title I of the ADA, 42 U. S. C. §12112(a), because she no longer held or sought a job with the defendant. The Eleventh Circuit Court of Appeals affirmed the trial court.

The Supreme Court of the United States affirmed the the Eleventh Circuit in the case of Stanley v City of Sanford, Florida -No. 23–997 (June 2025).

Title I of the Americans with Disabilities Act bars employers from “discriminat[ing] against a qualified individual on the basis of disability in regard to . . . compensation” and other matters. 42 U. S. C. §12112(a). The statute defines a “qualified individual” as “an individual who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires.” §12111(8).

The question before the United States Supreme Court in this case concerns whether a retired employee who does not hold or seek a job is a “qualified individual.”

The Eleventh Circuit concluded that §12112(a) does not reach allegations of discrimination against a retiree “who does not hold or desire to hold an employment position” that she is capable of performing with reasonable accommodation. 83 F. 4th 1333, 1337 (2023).

But, the court acknowledged, not every court of appeals would agree. Like the Eleventh Circuit, the Sixth, Seventh, and Ninth Circuits (Weyer v. Twentieth Century Fox Film Corp., 198 F.3d 1104, 1112 (9th Cir. 2000) ) have said that Title I’s anti-discrimination provision “does not protect people who neither held nor desired a job with the defendant at the time of discrimination.” Id., at 1341.

But the Second and Third Circuits take a different view. As those courts see it, the ADA’s definition of “qualified individual” is “ambiguous,” and they have resolved that ambiguity “in favor of ” extending the statute to reach retirees like Ms. Stanley. Ibid.

SCOTUS resolved the circuit court conflict, and agreed with the Eleventh Circuit in this case, (and with California and the 9th Circuit which previously came to the same conclusion.) To prevail under the ADA §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.