In Karyn D. Stanley v. City of Sanford, Case Number 23-997, the U.S. Supreme Court held that former employees who are unable to fulfill their job duties due to disability may not bring an Americans with Disabilities Act (ADA) claim concerning changes to their post-employment health benefits. Seven of the nine justices agreed that the ADA prohibits discrimination only against employees who can complete their job duties, not those who are unable to work due to their disabilities.
The ADA states that the law covers individuals if they can perform the essential functions of their position or the position they are seeking with or without reasonable accommodation. According to Justice Neil Gorsuch, who wrote the opinion, Congress’s use of present-tense verbs in the language of the ADA made it applicable only to employees able to perform those essential functions.
A former Florida city firefighter, Karyn D. Stanley, who retired in 2018 because of Parkinson’s disease, filed suit against the city in 2020 due to a policy change that dramatically decreased healthcare benefits for disabled retirees. As a result of this change, Stanley claimed the loss of almost $200,000 in subsidized healthcare premiums that she had to pay out of pocket. She alleged that the policy change that significantly affected her benefits was discriminatory against former employees who could no longer work due to disability.
The U.S. Court of Appeals for the Eleventh Circuit dismissed Stanley’s appeal in 2023, holding that her inability to work due to her disability placed her outside of the ADA’s protections. The appellate court further pointed out that individuals were “qualified” under the ADA only if they could perform essential functions of the job that they either held or were seeking. The Eleventh Circuit’s approach aligned with similar decisions in the Sixth, Seventh, and Ninth Circuits. However, the Second and Third Circuit courts adopted the opposite approach, creating a split among the circuits. The Supreme Court has now resolved the split among appellate courts on this issue.
Justices Sonia Sotomayor and Ketanji Brown Jackson filed separate dissenting opinions to the majority decision, claiming that their fellow justices were reading the ADA too narrowly. Justice Jackson called the majority decision “illogical” in concluding that Congress intended employers to be able to avoid ADA requirements by making them inapplicable to workers who retired due to disability.
Justice Gorsuch also noted in the majority opinion that Stanley might have been able to bring an ADA claim as a qualified individual while still employed from 2016 to 2018 after being diagnosed with Parkinson’s. The federal government also filed an amicus brief adopting this argument and reiterated it during the January oral arguments before the high Court. However, Gorsuch stated that Stanley failed to raise the argument early in the case.
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