Stanley v. City of Sanford (2025):
The Supreme Court Imposes a Temporal Boundary on Who Qualifies as a “Qualified Individual” under ADA Title I

1. Introduction

Stanley v. City of Sanford, 606 U.S. __(2025), arose from a challenge to a Florida municipality’s post-employment health-insurance policy for disabled retirees. Karyn Stanley, a former firefighter who was forced to retire in 2018 because of Parkinson’s disease, alleged that the City violated the Americans with Disabilities Act (ADA) by giving markedly less medical coverage to disability retirees than to 25-year service retirees. The lower courts dismissed her suit, reasoning that once Stanley retired she was no longer a “qualified individual” protected by Title I of the ADA. The Supreme Court granted certiorari to resolve a deep and acknowledged circuit split as to whether ADA Title I reaches disability-based discrimination inflicted after an employee leaves the workforce.

2. Summary of the Judgment

In a 7–2 result (with only Parts I & II of Justice Gorsuch’s opinion commanding that majority), the Court affirmed the Eleventh Circuit and held:

• To prevail under 42 U.S.C. §12112(a), a plaintiff must plead and prove that, at the time the challenged act of discrimination occurs, she either (i) holds or (ii) seeks an employment position whose essential functions she can perform, with or without reasonable accommodation.
• Consequently, Title I does not reach pure post-retirement discrimination directed at former employees who neither hold nor desire a job with the defendant.

Because Stanley’s complaint alleged that the discrimination occurred only after her 2018 retirement, she failed to satisfy the “qualified individual” element and her ADA claim was properly dismissed.

Concurring opinions by Justices Thomas (joined by Barrett) and Sotomayor (in part) criticized separate aspects of the Court’s analysis, while Justice Jackson authored a lengthy dissent (joined in major part by Sotomayor) arguing that Title I protects retirees against discrimination in the distribution of benefits earned while they were working.

3. Detailed Analysis

3.1 Precedents Cited and Their Influence

• Robinson v. Shell Oil Co., 519 U.S. 337 (1997) – Title VII’s reference to “employees” can include former employees unless context suggests otherwise. The majority invoked Robinson to contrast Title I’s present-tense language (“holds or desires”) with Title VII’s broader “employee” term, bolstering the conclusion that Congress deliberately covered only current job-holders or seekers.
• Carr v. United States, 560 U.S. 438 (2010) – The Court reiterated that verb tense is a reliable textual marker of statutes’ temporal reach.
• Cleveland v. Policy Management Systems Corp., 526 U.S. 795 (1999) and Albertson’s, Inc. v. Kirkingburg, 527 U.S. 555 (1999) – Both opinions treated the ability to perform present job functions as central to an ADA plaintiff’s case, a theme the majority cited as fore­shadow­ing today’s holding.
• Hishon v. King & Spalding, 467 U.S. 69 (1984); Newport News v. EEOC, 462 U.S. 669 (1983) – Acknowledged for the proposition that retirement and health benefits are “compensation,” eliminating any need to debate that component.
• Lilly Ledbetter Fair Pay Act (2009) – Its tripartite timing rules (“adoption,” “application,” “affected by”) framed the majority’s reminder that a plaintiff might still prevail if discrimination occurred while she remained qualified.

3.2 The Court’s Core Legal Reasoning

1. Statutory Text & Verb Tense.
     Section 12111(8) defines a “qualified individual” in unmistakably present-tense terms (“holds,” “desires,” “can perform”). Reading that language in ordinary fashion, the Court concluded Congress meant to protect only those able and willing to work at the moment the discrimination occurs.
2. Structural Clues within Title I.
     Examples of “reasonable accommodation” (job restructuring, modified facilities) and of prohibited practices (employment tests, qualification standards) all presuppose an existing or potential employment relationship. That architecture, the Court said, would make little sense if retirees were covered.
3. Comparison with Title VII.
     Where Title VII wants to cover former employees, it uses broad nouns (“employee”) uncoupled from present-tense verbs. Congress’s different phrasing in the ADA therefore signals a different reach.
4. Rejected Counter-Arguments.
     • Stanley’s “conditional mandate” theory—treating the qualified-individual phrase as operative only when a plaintiff actually seeks work—was labelled “conceivable-but-convoluted.”
     • Surplusage concerns about §12112(b)(5)(A)’s “applicant or employee” language were answered by noting that some redundancy is tolerated and may still perform narrowing work.
     • Appeals to statutory purpose cannot override clear textual limits; if Congress dislikes the result, “it can change the law.”

3.3 Concurring & Dissenting Perspectives

• Thomas (J., joined by Barrett) – Agreed with Parts I–II but chastised counsel for a “bait-and-switch” that tried, after cert grant, to pivot to a different theory (discrimination during employment) that had been disavowed below.
• Sotomayor (J.) – Agreed that plaintiffs could succeed if subjected to discrimination while still qualified, but disagreed with the majority’s broader holding that retiree-only discrimination falls outside Title I.
• Jackson (J., dissenting, joined largely by Sotomayor) – Attacked the Court’s “pure textualism,” arguing that the qualified-individual definition was never designed to impose a temporal cut-off. She would treat retirement benefits as deferred compensation, so that any disability-based change to them inherently targets an individual “in [their] capacity as a qualified employee.”

3.4 Likely Impact of the Decision

• Narrowing of ADA Tools for Retirees.
    Retirees alleging discrimination after their employment ends must now look to other laws (e.g., §504 of the Rehabilitation Act, state anti-discrimination schemes, ERISA anti-cutback provisions, equal-protection §1983 suits) rather than Title I.
• Employer Policy Incentives.
    Employers may defensively strip disability-specific language from benefit plans, equalizing downward (i.e., reducing everyone’s benefits) to avoid ADA liability.
• Litigation Strategy Shifts.
    Plaintiffs’ lawyers will plead with far greater precision: Was the discriminatory policy adopted, applied, or did the claimant “become subject” to it while still employed? Complaints will include diagnosis dates and spell out periods of working-while-disabled to satisfy the new rule.
• Pressure on Congress.
    Given the bipartisan history of disability legislation, today’s restriction may spur an ADA amendment or an independent statute expressly protecting retirees.
• Circuit Split Resolved.
    The Second and Third Circuits must now abandon precedents (e.g., Kaufman, Ford) that allowed Title I suits by retirees.

4. Complex Concepts Simplified

• Qualified Individual (ADA). A person who currently holds or is applying for a specific job and can do its core tasks if reasonable adjustments are made. Under Stanley, retirees who no longer seek work are excluded.
• Reasonable Accommodation. An adjustment to the job or workplace (modified schedule, adaptive equipment) that enables a disabled person to perform essential duties without imposing “undue hardship” on the employer.
• Disparate-Treatment Claim. A lawsuit alleging intentional unequal treatment “because of” disability, as opposed to a neutral policy that merely has a disproportionate impact.
• Lilly Ledbetter Timing Rule. For compensation claims, discrimination occurs each time (1) a policy is adopted, (2) someone becomes subject to it, or (3) the policy is applied to them (e.g., a diminished paycheck).
• Deferred Compensation. Benefits (pension, retiree health) earned while working but received later. The majority assumes such benefits are “compensation” but limits who may sue.

5. Conclusion

Stanley v. City of Sanford delivers a clear—but controversial—rule: the ADA’s Title I shield extends only to those who, at the moment of discrimination, are in or seeking the workplace. Retirees harmed solely after leaving the jobsite must seek protection elsewhere, or wait for Congress to act. Practically, the opinion rewrites the litigation playbook for disability benefit disputes, forces lower courts to jettison retiree-friendly precedent, and ignites policy debates about the adequacy of the ADA’s original design in an era when postemployment benefits remain central to economic security. Whether Congress elects to restore protection for retirees will determine whether Stanley’s temporal limitation becomes a permanent fixture in American disability law or a prompt for legislative repair.