In a 7–2 decision issued June 21, 2025, the U.S. Supreme Court held that the Americans with Disabilities Act (ADA) does not cover former employees who are no longer able to work due to a disability. In Stanley v. City of Sanford, the Court ruled that Title I of the ADA applies only to individuals who can perform, or seek to perform, the essential functions of the job at the time of the alleged discrimination.
The case centered on a retired Florida firefighter who alleged that changes to post-employment health benefits discriminated against her based on her disability. The Court disagreed, finding that because she was no longer employed or seeking employment at the time, she was not a “qualified individual” under the ADA. Writing for the majority, Justice Gorsuch emphasized that Congress' use of present-tense language in the statute limits protections to current or prospective employees, not retirees.
For employers, this decision is an important clarification. It affirms that ADA obligations under Title I do not extend indefinitely after an employee separates from service due to disability. The Court did acknowledge that other legal avenues, such as claims tied to the time when a disabled employee is still working, may still be viable in some cases. Employers should continue to maintain fair and consistent benefit policies and ensure ADA compliance for active employees. This ruling helps limit long-term liability and supports employers' ability to make practical, lawful decisions about retirement and benefits.
If you have questions regarding this decision or for help revisiting your policies, please contact Dani Smid or your BrownWinick attorney. Special thanks to summer associate Audrey Gruss for her assistance with this article.