Supreme Court Rules ADA Does Not Protect Retirees

On June 20, 2025, the U.S. Supreme Court held in Stanley v. City of Sanford that retirees are not “qualified individuals” under the Americans with Disabilities Act (ADA) and therefore cannot bring employment discrimination claims based on events that occurred after they retire. Writing for the majority, Justice Neil Gorsuch explained that ADA protections under Title I apply only to individuals who currently hold a job or are seeking employment. Thus, once an individual has fully retired and is no longer in the workforce, they fall outside the scope of the statute.

The facts in Stanley were fairly straightforward. The plaintiff, a retired firefighter, sued the City of Sanford, Florida, alleging that its policy of providing only 24 months of health insurance coverage to those who took early retirement due to disability – while offering lifetime coverage to those who retired at the standard age of 65 – was discriminatory. The policy had been in place since 2003, but the firefighter challenged it only after retiring due to her disability.

The Court rejected her claim, emphasizing that the ADA protects people, not benefits, and that Congress intended to reserve Title I claims only to current employees or job applicants that could plead and prove they could perform the essential functions of their current or sought-after job with or without accommodation. Importantly, the Court noted that had the plaintiff brought her claim while still employed or during the period between her diagnosis and her retirement – when she still could have been considered a “qualified individual” – her claim might have been viable.

This decision effectively forecloses ADA claims by retirees for alleged post-retirement discrimination, marking a clear shift in the legal landscape, particularly for employers in the Second and Third Circuits (including New York and New Jersey), where prior precedent had extended ADA protections to retirees.

Key Takeaways for Employers: 

While the ADA no longer provides a basis for post-retirement disability discrimination claims, employers should remain attentive to obligations under other laws such as the Employee Retirement Income Security Act (ERISA), as well as State and local discrimination laws. Employers should review retirement-related policies, especially those affecting individuals with disabilities, to ensure clarity and consistency. Communicating benefit structures clearly during the transition to retirement may also help prevent confusion and mitigate potential claims under other legal theories.