Decision Alert: Retirees Cannot Bring A Claim Under The ADA As A "Qualified Individual"

In Stanley v. City of Sanford, the Court held 7-2 that a retiree is not a "qualified individual" under Title I of the Americans with Disabilities Act of 1990 (ADA), as the statute applies only to current employees or those actively seeking employment.

As previewed in Dykema's February 2025 issue, the case stemmed from a modification to Karyn Stanley's retirement-benefits package. Stanley began working as a firefighter for the City of Sanford, Florida, in 1999. At that time, the City provided health insurance until the age of 65 for those who either (1) retired with 25 years of service, or (2) retired early due to a disability. In 2003, the City revised this policy, offering full insurance benefits only to those with 25 years of service. Individuals retiring early due to disability, like Stanley, were limited to 24 months of health insurance—unless they became eligible for Medicare sooner.