In Stanley v. City of Sanford, Florida, the U.S. Supreme Court considered whether the Plaintiff, Karyn Stanley (the Plaintiff), a retired firefighter, could bring a claim of discrimination for changes to post-employment healthcare benefits. The Plaintiff was hired by the City of Sanford, FL (the City) in 1999. At the time of her hire, the City policy provided health insurance until age 65 to those retirees who had 25 years of service or who retired earlier due to a disability.  Subsequently, the City changed its retiree healthcare benefits policy for those who retired due to disability to 24 months post-retirement.

At some point prior to reaching 25 years of service, the Plaintiff developed Parkinson’s disease and  was forced to retire earlier than she expected. Upon her disability retirement, she qualified for up to 24 months of retiree health insurance pursuant to the City’s current retiree health insurance policy.  The Plaintiff sued the City claiming  the policy was discriminatory as it treated those who retired after 25 years and those who retired due to a disability differently.

The District Court held, in part, that her claim of discrimination under the ADA must be dismissed because, as a retiree, she was not a “qualified individual.” The Eleventh Circuit Cout of Appeals affirmed. The U.S. Supreme Court, noting disagreement among the circuits, granted certiorari.

The U.S. Supreme Court held the Plaintiff could not bring an ADA claim of discrimination as she was no longer a  “qualified individual”  protected under the ADA. It went on to explain that the purpose of the ADA is to protect employees or individuals who, “at the time they suffer discrimination,” are able to perform essential functions of the position they hold or seek, with or without reasonable accommodation.

The Court found the applicable ADA provisions are intended to protect employees or job seekers rather than retirees who neither hold a position nor are seeking  employment. The Court further held that an individual who can “no longer do the job” is not a qualified individual pursuant to the ADA and falls outside of its protections. Accordingly, the Court concluded, the purpose of the ADA, to provide reasonable accommodations for employees to successfully perform job duties, “made no sense” with respect to retirees.

However, the Court indicated that while the ADA does not protect the Plaintiff from discrimination with respect to post-employment benefits in this case, there are circumstances where ADA protections could be implicated for retirees.

The Court noted the ADA could potentially apply to a retiree upon a showing a policy is discriminatory to a qualified individual (1) when adopted; (2) when affected by its application; or (3) who becomes subject to a discriminatory decision or practice; none of which were applicable to facts of this case. The Court also discussed other statutes that may provide more robust protections to a retiree, such as the Rehabilitation Act or applicable state laws.

This case illustrates the often-complicated interactions between statutory protections and benefit policies.  If you or your organization have questions regarding the impact of potential benefit modifications, contact Wiley Reber Law for legal advice that works.