On June 20, 2025, the United States Supreme Court issued its decision in Stanley v. City of Sanford, holding that retirees are not protected under the Americans with Disabilities Act (“ADA”) for claims related to post-employment benefits. This decision resolves a circuit split and clarifies that the ADA does not extend to individuals who are not currently employed or seeking employment at the time of the alleged discrimination.

The City of Sanford (“City”) employed Stanley until she developed a disability that forced her to retire. Initially, the City offered health insurance until age 65 for retirees with 25 years of service and for those who retired earlier due to disability. In 2003, the City changed its policy to limit the coverage of employees who retired early due to a disability to 24 months while it maintained the original policy for those with 25 years of service. Although not mentioned in Ms. Stanley’s pleadings, she developed a disability in 2016 which forced her to retire two years later. After retiring, she sued the City claiming that the policy violated the ADA by providing different health-insurance benefits to those who retire with 25 years of service and those who retire due to disability. The district court granted the City’s motion to dismiss, and the Eleventh Circuit affirmed.

In rendering their decision, the Supreme Court only considered the pleadings and focused on the interpretation of “qualified individual” under Title I of the ADA. The Court emphasized that the ADA’s protections apply only to those who are employed or actively seeking employment when the discriminatory act occurs. The statute’s use of present-tense verbs such as “holds,” “desires,” and “can perform” was pivotal in the Court’s analysis, underscoring that the ADA is intended to protect current employees or job seekers, not retirees. However, the Court did mention that had Ms. Stanley provided detail of the timing and nature of her disability in her pleadings and had she not stated in her brief that she did not claim to be impacted by the discriminatory policy during her employment, then her case may have survived the motion to dismiss.  In other words, had Ms. Stanley been able to allege and prove that she was disabled and a “qualified individual” when the City adopted a discriminatory retirement-benefits policy, she would have been in a better position to pursue the claim.

This ruling provides clarity for employers regarding the scope of the ADA, particularly in relation to the ADA’s impact on retiree benefits. However, it is crucial for employers to remember that almost every state has its own set of employment discrimination statutes which may well apply to retirees based on how they are written.