Stanley v. City of Sanford, Florida

LII note: The U.S Supreme Court has now decided Stanley v. City of Sanford, Florida

Issues

Under the Americans with Disabilities Act, does a former employee lose her right to sue over discrimination with respect to post-employment benefits solely because she no longer holds her job?

Oral argument:
January 13, 2025
Court below:
United States Court of Appeals for the Eleventh Circuit

This case asks the Supreme Court whether a former employee can sue over discrimination under the Americans with Disabilities Act after they have already left their job. Stanley argues that retirees, such as herself, have the right to sue regardless of whether they meet the definition of a qualified individual, and alternatively, that she qualifies as an eligible qualified individual even though she is suing post-employment. Sanford contends that Stanley did not previously argue that retirees have the right to sue regardless of their status as qualified individuals and has therefore waived her right to make this argument. Moreover, Sanford maintains that Stanley does not meet the definition of a qualified individual because Congress did not intend for employees to sue under the ADA post-employment. The outcome of this case has implications for disabled employees’ retirement benefits and the economic freedom of both employers and cities.

Questions as Framed for the Court by the Parties

Whether, under the Americans with Disabilities Act, a former employee — who was qualified to perform her job and who earned post-employment benefits while employed — loses her right to sue over discrimination with respect to those benefits solely because she no longer holds her job.

Facts

In 1999, Karyn Stanley became a firefighter for the City of Sanford, Florida and served for over fifteen years before being diagnosed with Parkinson’s disease in 2016. She continued working for two more years but ultimately retired in late 2018 due to the disease and its physical challenges.

When Stanley joined in 1999, the policy in effect provided free health insurance for disabled retirees until age 65. However, Sanford changed the policy in 2003, requiring retirees to complete 25 years of service to qualify for health insurance until 65. Under the new policy, disabled retirees like Stanley, who do not meet the 25-year service requirement, only receive two years of healthcare. Stanley was unaware of these changes until her retirement, leaving her responsible for her own health insurance starting in late 2020.

In April 2020, Stanley filed a lawsuit against Sanford, seeking to show she was entitled to health care until the age 65. Stanley argued that the decision to limit health insurance was discriminatory against people with disabilities, and thus, violated Title I of the Americans with Disabilities Act (“ADA”) as well as other state and federal laws.

Congress enacted the ADA in 1990 to remedy widespread discrimination against disabled individuals. Title I of the ADA prohibits employers from discriminating against a “ qualified individual ” on the basis of disability in areas such as job applications, hiring, promotion, termination, or employee compensation. A “qualified individual” is defined as someone who, with or without reasonable accommodations , can perform the job position that they hold or desire.

The United States District Court for the Middle District of Florida dismissed Stanley’s claims because Stanley was no longer employed at Sanford, so the ADA no longer applied. The district court held that the alleged discrimination occurred entirely post-employment and was not covered by the ADA, as she was no longer a qualified individual.

Stanley appealed to the United States Court of Appeals for the Eleventh Circuit , which previously held , in Gonzales v. AARP , that former, retired employees cannot sue under the ADA, and both parties agreed that Stanley’s ADA claim controls all Stanley’s other claims. However, Stanley argued that a Supreme Court decision, which addressed a similar issue under Title VII of the Civil Rights Act , should take priority over the Eleventh Circuit’s earlier ruling . The Eleventh Circuit rejected this argument, noting key differences between the statutes. Specifically, Title VII addresses retaliation and does not include Title I’s definition of a “qualified individual.” Stanley also contended that recent amendments to the ADA supported her position, but the Eleventh Circuit held the amendments do not change its previous interpretation, as the statute still defines a “qualified individual” as someone who holds or desires the job position. Therefore, the Eleventh Circuit affirmed the district court’s holding, ruling that Stanley did not have a valid claim under the ADA because she did not meet the definition of a qualified individual as she neither held nor desired the job position.

Accordingly, on January 23, 2024, Stanley petitioned the Supreme Court of the United States to hear her case. On June 24, 2024, The Supreme Court granted certiorari to hear only about the issue of whether Sanford violated the ADA.

Analysis

WHEN THE DISCRIMINATORY ACT OCCURRED

Stanley argues that the Eleventh Circuit misunderstands the ADA, which permits anyone alleging disability discrimination, including retirees, to sue if affected by discriminatory policies adopted during their employment. Stanley contends that the ADA’s Enforcement provision states that “any person alleging discrimination on the basis of disability” under Title I has access to the full range of remedies, without requiring the plaintiff to be a “qualified individual.” Stanley proposes applying a “ zone-of-interests ” test, arguing that the Enforcement provision allows suits as long as they’re within the statute’s purpose. Stanley explains that this “zone-of-interest test” ensures the plaintiff is asserting an interest sought to be protected by the ADA. Under this test, Stanley claims she qualifies because the ADA seeks to prevent discrimination in job-related benefits, which include post-employment benefits like retirement. Stanley concludes that retirees, such as herself, have the right to sue regardless of whether they meet the definition of a qualified individual.

Stanley alternatively argues that she was a qualified individual when the discriminatory act occurred—Sanford’s adoption of the alleged discriminatory retirement plans in 2003. Stanley emphasizes that she was employed by the city at that time, held the desired job, and was subject to a policy that allegedly discriminated compensation between employees based on disability. Stanley further contends that the Lilly Ledbetter Fair Pay Act of 2009 (“Ledbetter Act”), as part of Title I, allows retirees to sue when they are later affected by the discriminatory benefit plans adopted during their employment. Under this framework, Stanley asserts that she can now sue because, although the discriminatory decision occurred in 2003, it did not affect her until 2020. By combining the ADA and the Ledbetter Act, Stanley argues she is entitled to bring suit because she was a qualified individual when the discriminatory act occurred, even if the harm materialized years later.

Sanford argues that Stanley’s first argument—that the ADA permits former employees to sue over retirement benefits—attacks a straw man , as the Eleventh Circuit did not bar such suits, and the Supreme Court did not agree to answer that question. Sanford emphasizes that the case instead concerns whether post-employment disability discrimination falls under the ADA. Sanford contends that Stanley waived this argument by failing to raise it in lower courts and improperly introduced the argument in her reply brief. Even if the argument was not waived, Sanford argues that the ADA requires discrimination to target a “qualified individual.” Therefore, Sanford contends that even if Stanley can sue under the Enforcement provision, she must prove the violation involved a qualified individual, which Sanford asserts she has not done.

Sanford argues that Stanley’s second argument is also beyond the scope of the Supreme Court’s review. Specifically, Sanford asserts that Stanley is now contending that the discrimination was not post-employment, contradicting the Eleventh Circuit’s determination, which the Supreme Court is not reviewing. Even if the Supreme Court addresses this issue, Sanford notes that Stanley previously conceded that she could not have sued in 2003 because she was not disabled at the time and therefore lacked grounds to sue while employed. Further, Sanford contends that Stanley was not harmed in any way that would allow a lawsuit in 2003 when the change occurred, because she was not getting retirement benefits as well as not being disabled. Additionally, Sanford argues the Ledbetter Act does not apply because it allows claims only if the initial claim existed. Sanford maintains that since Stanley admitted she could not have sued in 2003, there is no claim that could re-accrue through the Ledbetter Act in 2020.

ARE RETIREES WITHIN THE DEFINITION OF A “QUALIFIED INDIVIDUAL”

Stanley argues that even if the alleged discrimination is entirely post-employment, retirees still meet the definition of a “qualified individual” under the ADA, contrary to the Eleventh Circuit’s interpretation. Stanley points out that the ADA’s definition leads with whether the individual “ can perform the essential functions” (emphasis added), not if the individual “holds or desires” the job. Stanley contends that if the definition required a person to “hold or desire” the job, as the Eleventh Circuit suggested, the statute would explicitly impose that requirement by listing it first as a condition . Instead, Stanley emphasizes that the plain language focuses on capability, not current or desired employment status. Stanley asserts this “can” test makes sense with Congress’s objectives in creating the “qualified individual,” because Congress wanted to ensure employers are not forced to hire or retain people who are incapable, even with reasonable accommodations, of performing the essential functions of the job.

Stanley argues that retirees satisfy the “can” test because as a retiree, they are not required to perform any job functions, meaning there are no essential functions to assess. Stanley states that this is only common sense; since a retiree holds no job, they cannot be unable to perform the job they currently hold, so they must pass the test. Stanley contends that applying the “qualified individual” requirement to retirees so that they fail leads to bizarre results that do not match the intention of Congress. Stanley claims that the Eleventh Circuit’s reading would allow employers to discriminate openly against retired employees, which contradicts the ADA’s purpose of preventing disability discrimination.

Sanford argues that to meet the definition of a “qualified individual,” the person must hold or desire a job at the time of the discriminatory act. Sanford emphasizes that Congress intentionally used the present tense in the “qualified individual” definition, adding a “temporal qualifier” that excludes retirees. Citing Robinson , Sanford notes that the Supreme Court highlighted Title VII lacks a temporal qualifier, unlike the ADA, leading to a difference in who is allowed to sue. Sanford also criticizes Stanley’s “can” test as unworkable, claiming it would allow individuals to avoid proving their ability to perform a job if they say they don’t desire the job. Finally, Sanford asserts the true purpose of the “qualified individual” language is to protect disabled individuals who currently work, want to work, and can work despite their disabilities, not to protect employers.

Sanford argues that retirees cannot satisfy the “qualified individual” requirement because they neither hold nor seek a job at the time of post-employment discrimination. Sanford also disputes Stanley’s characterization of the Eleventh Circuit’s holding, emphasizing that the court did not bar former employees from suing but required plaintiffs to be “qualified individuals” at the time of the discriminatory act. Additionally, Sanford highlights that Congress may have intentionally excluded retirees from the ADA’s coverage because other federal statutes, like ERISA and the Social Security Act , along with common law remedies , already protected retirement benefits when the ADA was enacted. Sanford concludes that the Eleventh Circuit’s interpretation does not permit employers to freely discriminate against retirees, as preexisting remedies address those issues, allowing Congress to prioritize workplace disability discrimination against capable individuals.

Discussion

DISABILITY PROTECTIONS

The National Employment Lawyers Association and the National Employment Law Project (“NELA”), in support of Stanley, argue that the ADA was created to broadly protect people with disabilities and their civil rights. NELA asserts that the ADA should bring persons with disabilities into the economic and social mainstream of American life, and finding for Stanley would protect this vulnerable group. . Furthermore, the International Association of Fire Fighters (“IAFF”) contends that firefighters like Stanley are particularly affected by this decision and should be granted additional protections, as they are more likely to contract diseases on the job and retire early. The AARP and AARP Foundation (“AARP”) states that ruling in favor of Stanley would benefit millions of older adults with disabilities by providing them with greater access to retirement benefits. Conversely, the AARP maintains that ruling against Stanley would leave this group without a legal remedy and result in a “staggering” amount of health care costs that they would be unable to manage during retirement.

The Center for Workplace Compliance (“CWC”), in support of Sanford, counters that Stanley’s position does not benefit people with disabilities but instead harms them. Furthermore, the CWC asserts that because employers are not legally required to provide disability benefits, they may discontinue offering these benefits if compelled to expand their payments. The CWC contends that this would result in disabled individuals receiving less funding than they would have previously. The Chamber of Commerce of the United States of America further argues that reducing benefits would make these fields of work less appealing to disabled individuals, ultimately harming them by discouraging their entry into the workforce.

ECONOMIC EFFECTS: EMPLOYER VERSUS THE PUBLIC BURDEN

Main Street Alliance, in support of Stanley, argues that upholding the lower court’s decision would harm employers by limiting their ability to negotiate for health benefits. Main Street Alliance contends that many individuals rely on their health benefits, arguing that these benefits are a crucial factor for prospective employees when choosing a job. According to Main Street Alliance, changing an employee’s benefits after they have accepted a job will undermine trust between employees and employers. Main Street Alliance asserts that, as a result, fewer employers would offer these benefits to people with disabilities. Additionally, Main Street Alliance states that even if employers do not intend to cut benefits for disabled former employees, the possibility of future changes to retirement plans reduces the value of these benefits for prospective employees, potentially discouraging individuals from entering various industries of work. Main Street Alliance explains that this could also harm employers who intend to provide benefits to former employees, as competitors could gain a short-term advantage by cutting benefits to disabled employees, thus securing an immediate cash benefit.

The National League of Cities and others (“NLOC”), in support of Sanford, counters that local governments should have the discretion to make economic decisions that best serve the public interest. The NLOC contends that governments must have discretionary policy-making abilities to effectively allocate scarce public resources. According to the NLOC, reversing the lower court’s decision would prevent governments from adapting their policies to the changing economic landscape, resulting in rigid, inflexible rules that do not serve the general population. The NLOC argues that this impact on cities' economies could be devastating, as it has been in similar situations, like Detroit’s crippling bankruptcy that caused billions of dollars of harm to the city’s creditors. Therefore, the NLOC contends that it is financially prudent to implement certain retirement cuts now to avoid more significant economic consequences and cuts later.

Conclusion

Authors

Written by: Abigail Breneisen and Sarah Chang

Edited by: Eric Yang

Additional Resources