Supreme Court Decides Stanley v. City of Sanford

On June 20, 2025, the Supreme Court of the United States issued a decision in Stanley v. City of Sanford, No. 23-997, holding that a plaintiff suing for employment discrimination under Title I of the ADA, 42 U.S.C. § 12112(a), must plead and prove she is a “qualified individual,” defined as “an individual who, with or without reasonable accommodation, can perform the essential functions” of the job that the person “holds or desires.” Therefore, the statute does not extend to retirees.

Petitioner is a former firefighter who was employed by the City of Sanford, Florida. When Petitioner commenced employment, the City provided health insurance benefits up to age 65 for two classes of retirees: individuals that had worked for 25 years, and individuals that retired earlier due to a disability. While Petitioner was employed, the City changed its policy and reduced the period of health insurance benefits offered to disabled retirees to a period of 24 months. Petitioner retired prior to 25 years of service, due to a disability, and was thus entitled only to 24 months of coverage. She sued under Title I of the ADA, which prohibits discrimination in employment on the basis of a disability.

The district court ruled in favor of the City, holding that Title I of the ADA did not extend to claims of discrimination brought by retirees. The district court reasoned that the definition of a “qualified individual,” 42 U.S.C. § 12111(8), was limited only to current or prospective employees. The Eleventh Circuit affirmed.

The Supreme Court affirmed in a split opinion. The majority examined the text of Section 12111(8), specifically the usage of the present-tense verbs “holds or desires” to conclude that Congress intended to reserve Section 12112(a) claims only to current employees or job applicants that could plead and prove they could perform the essential functions of their current or sought-after job with or without accommodation. The Court looked to examples of “accommodations” contemplated by Title I, which included “existing facilities used by employees,” and “training materials or policies,” none of which could apply to retirees. The Court further contrasted the ADA with other federal statutory schemes, including Title VII of the Civil Rights Act, which also addresses employment discrimination, but do not contain the present-tense limiters “holds or desires” or “can perform.”

Justice Gorsuch delivered the opinion of the Court with respect to Parts I and II of the opinion, and an opinion with respect to Part III, which was joined by Justice Alito, Justice Sotomayor, and Justice Kagan. Justice Thomas wrote an opinion concurring in part and concurring in the judgment. Justice Sotomayor wrote an opinion concurring in part and dissenting in part. Justice Jackson wrote a dissenting opinion, which was joined by Justice Sotomayor as to Parts III and IV, except for Footnote 12.