Beyond the Job: Stanley v. City of Sanford and the Temporal Limits of “Qualified Individual” Status Under the ADA

Introduction

Stanley v. City of Sanford, 606 U.S. ___ (2025), is the Supreme Court’s first major pronouncement on how far Title I of the Americans with Disabilities Act of 1990 (ADA) reaches once an employment relationship has ended. Karyn D. Stanley, a Florida firefighter forced into disability retirement, alleged that the City of Sanford violated the ADA when it curtailed her post-retirement health-insurance subsidy from coverage until age 65 to only 24 months. Her lawsuit squarely raised a question that had splintered the circuits for two decades: Does Title I protect a former employee who no longer holds or seeks a job with the defendant when the challenged discrimination affects retirement-related compensation?

Answering “No,” a seven-Justice majority affirmed dismissal of her ADA claim, holding that a plaintiff suing under §12112(a) must be a “qualified individual” at the moment of the discriminatory act, and that the statutory definition of that term—someone who “holds or desires” an employment position and “can perform” its essential functions—excludes retirees. Three concurring and two dissenting opinions expose sharp methodological disagreements about textualism, statutory purpose, and the Court’s role in shaping issues preserved for review.

Summary of the Judgment

Holding. Title I of the ADA does not reach disability-based discrimination that occurs when the plaintiff neither holds nor seeks a job with the defendant; retirees are not “qualified individuals” within §12111(8). The Eleventh Circuit’s dismissal of Stanley’s claim is affirmed.
Lead Opinion. Justice Gorsuch (Parts I–II for a 7-Justice majority; Part III for a 4-Justice plurality) anchors the result in textual analysis of verb tenses (“holds, desires, can perform”), the statutory definition of “reasonable accommodation,” and comparative readings of Title VII.
Concurring Opinions.
- Justice Thomas (joined by Barrett) agrees on the merits but criticizes parties that change theories after certiorari and cautions against advisory pronouncements.
- Justice Sotomayor, joined in part by Justice Jackson, agrees that some pre-retirement theories might survive but rejects the majority’s broad exclusion of retirees.
Dissent. Justice Jackson (joined in relevant part by Sotomayor) argues that the majority mis-reads the qualified-individual definition, ignores ADA purposes, and unnecessarily volunteers an answer to a question not implicated by Stanley’s factual allegations.

Analysis

1. Precedents Cited and Their Influence

Cleveland v. Policy Management Systems Corp., 526 U.S. 795 (1999) – Demonstrated the Court’s assumption that an ADA plaintiff must show current ability to perform job functions; majority quotes Cleveland to illustrate that someone who “can ‘no longer do the job’ ” falls outside Title I.
Robinson v. Shell Oil Co., 519 U.S. 337 (1997) – Interpreted “employee” in Title VII to include former employees. The majority distinguishes Robinson by stressing that Title VII lacks verbs restricting timing whereas the ADA’s definition is yoked to present-tense verbs.
Carr v. United States, 560 U.S. 438 (2010) – Cited for the proposition that verb tense can reveal statutory temporal reach.
Hishon v. King & Spalding, 467 U.S. 69 (1984) & Newport News Shipbuilding, 462 U.S. 669 (1983) – Support that retirement plans are “compensation,” a point undisputed by the parties.
Raytheon v. Hernandez, 540 U.S. 44 (2003) and others – Provide doctrinal backdrop for disparate-treatment ADA claims.

2. Legal Reasoning

a. Textual Focus

The majority’s interpretive engine is the definition of “qualified individual” (§12111(8)): a person who “holds or desires” a position and “can perform” its essential functions. Present-tense verbs, says the Court, signal contemporaneity; Congress protected only those currently capable of doing (or applying for) the job. This reading, the Court contends, harmonizes with:

The examples of discrimination in §12112(b) (qualification standards, employment tests) that logically apply to applicants or employees, not retirees.
The definition of “reasonable accommodation” (job restructuring, modified equipment) aimed at enabling job performance, not post-employment benefits.
Contrast with Title VII’s generic “employee” language, which the Court has allowed to cover former employees only where verb tenses do not suggest otherwise.

b. Rejection of Alternative Readings

Petitioner and the dissent urged a conditional-mandate view: the “qualified individual” clause matters only if a plaintiff complains about hiring, promotion, or discharge; if the claim concerns post-employment benefits, capability to do the job is irrelevant. The Court labels that reading “conceivable-but-convoluted,” preferring what it calls the more “ordinary” interpretation.

The Court also rebuffs surplusage arguments (that its reading renders “applicant or employee” redundant in §12112(b)(5)(A)), noting redundancy is sometimes tolerated and the phrase may still serve a narrowing role.

c. Purpose, Policy, and Legislative Design

Acknowledging that the ADA’s overarching goal is to eradicate disability discrimination, the Court nonetheless insists that specific textual limits—here, the “qualified individual” requirement—are part of the legislative compromise. Other statutes (the Rehabilitation Act, §1983 Equal Protection, state laws) remain available to protect retirees, and Congress is free to expand the ADA if desired.

d. Procedural Layer: Issue Preservation

The majority’s Part III addresses Stanley’s alternative theory—discrimination while she was still employed—only to conclude it was (i) inadequately pleaded and (ii) disclaimed in the Eleventh Circuit. Justice Thomas chastises the Court for even exploring that theory, warning against “bait-and-switch” petitions that pivot after certiorari is granted. Justice Sotomayor and Justice Jackson counter that Stanley’s pleadings plausibly allege she was disabled and working when the City’s policy applied, and that the Court should have resolved the case on that narrower ground or dismissed the writ as improvidently granted.

3. Impact on Future Litigation and Employment Practices

Post-Employment Disability Claims. Retirees and other former employees who neither hold nor seek a job with the defendant now cannot use Title I to challenge discriminatory changes to pensions, retiree health benefits, or analogous forms of deferred compensation.
Strategic Timing by Employers. An employer can lawfully wait until an employee retires to implement a benefit reduction that singles out disabilities without fear of Title I liability (though other laws may apply). This creates potential “perverse incentives” noted by the Seventh Circuit in Morgan (cited by the Court).
Pleading Roadmap. Plaintiffs seeking to salvage ADA claims must allege that the discriminatory policy first applied while they were still working and able to perform essential functions. The decision thus shifts the focal point of ADA retiree-benefit litigation to adoption-or-application timing.
Legislative Pressure. The Court invites Congress to amend Title I if broader retiree coverage is desired. Advocacy groups may now push for an “ADA Retiree Fairness Act” or similar amendment.
Role of Other Statutes. Litigators will turn increasingly to the Rehabilitation Act (for public-sector defendants), ERISA §510, ADEA, state anti-discrimination laws, and constitutional equal-protection claims under §1983.

Complex Concepts Simplified

Title I of the ADA. The portion of the ADA dealing with employment discrimination. It uses a burden-shifting framework similar to Title VII.
Qualified Individual. Someone who can perform the essential functions of a job they hold or want, with or without reasonable accommodation.
Reasonable Accommodation. Workplace adjustments (modified schedules, adaptive equipment) that allow a person with a disability to perform job duties, unless they impose undue hardship on the employer.
Disparate Treatment vs. Disparate Impact. Stanley alleged disparate treatment—being intentionally treated worse because of disability. Disparate impact would involve a neutral policy disproportionately harming disabled workers.
Lilly Ledbetter Fair Pay Act. A 2009 law stating that each paycheck or benefit distribution affected by a discriminatory decision resets the limitations clock—key to determining when an ADA cause of action accrues.
Issue Preservation. Appellate courts generally refuse to consider arguments not properly raised below. Justice Thomas’s concurrence underscores the principle.

Conclusion

Stanley v. City of Sanford narrows ADA coverage by grafting a temporal requirement onto the “qualified individual” definition: ADA plaintiffs must hold or seek the job at the moment of discrimination. The decision provides clarity for employers but curtails a significant avenue of redress for retirees facing disability-based benefit reductions. Unless Congress intervenes, protection for post-employment disability discrimination will depend on alternative federal statutes, constitutional claims, or the patchwork of state laws—leaving disabled retirees with uneven safeguards nationwide. For practitioners, the opinion is a cautionary tale: plead timing with precision, preserve all theories early, and anticipate that “retiree-only” ADA claims are no longer viable under Title I.