The Supreme Court ruled in an 8-1 decision on Friday that retirees are not “qualified persons” under the Americans with Disabilities Act (ADA) and therefore cannot bring ADA suits over issues that occur in retirement.
The appellant in the case, Karyn Stanley, took disability retirement from the City of Sanford, Florida’s fire department two years after being diagnosed with Parkinson’s Disease. Under city policy when she was hired, the city would pay 75 percent of her medical insurance premium post-retirement until she turned 65. However, the policy changed in 2003, reducing the duration of payments to two years for those who retire due to disability.
Stanley sued under the ADA, alleging discrimination based on her disability. The ADA is a broad civil rights law that prohibits discrimination against persons with disabilities in employment and access to public services and accommodations. The act defines a disability as a condition that substantially limits one or more major life activities.
Writing for the majority, Justice Neil Gorsuch noted that Stanley sued under Title I of the ADA. Section 12112(a) provides Title I’s general liability rule for disability discrimination. The section makes it unlawful for a covered employer to “discriminate against a qualified individual on the basis of disability in regard to … compensation,” which includes retirement benefits. However, section 12111(8) defines a qualified individual as someone “who, with or without reasonable accommodation, can perform the essential functions of the employment position that [she] holds or desires.” Gorsuch wrote, “the statute protects people, not benefits, from discrimination. And the statute also tells us who those people are: qualified individuals, those who hold or seek a job at the time of the defendant’s alleged discrimination.”
He also examined scenarios in which Stanley’s case could have had a different outcome. If she could have alleged the presence of discriminatory policies while she was still a qualified individual, or if she had worked for any period with some disability, then her case could have proceeded.
Justice Ketanji Brown Jackson dissented, writing:
Retirement benefits are essential building blocks of the American Dream. Workers typically earn these benefits on the job and reap the rewards after leaving the workforce. Congress has long understood that, by enabling workers to retire with dignity, independence, and security, retirement benefits are a critical aspect of job-related compensation. Thus, no one seriously disputes that the Americans with Disabilities Act of 1990 … prohibits disability discrimination with respect to retirement benefits.
She continued:
It is illogical to conclude that, while Congress wanted to protect against discrimination with respect to retirement benefits, it crafted a statute that implicitly cuts off those protections the moment a worker last clocks out. Holding as much allows employers to evade Title I’s retirement-benefit protections by bait and switch. They need not refrain from discrimination; all they have to do is wait.
The Supreme Court also ruled earlier this month that schoolchildren bringing ADA suits do not have to show “bad faith or gross misjudgment” to bring education-related discrimination claims. Also,in April 2022, the Court held that emotional distress damages were not available under the ADA.
