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Supreme Court ‘clarifies’ ADA Title I protections for retired workers

August 2025 employment law letter
Authors: 

Patrick Bernal and Joseph Robertson, Holland & Hart LLP

On June 20, 2025, the U.S. Supreme Court issued its long-awaited opinion in Stanley v. City of Sanford, addressing the scope of protections available to retired workers under Title I of the Americans with Disabilities Act (ADA). Generally, the ADA prohibits disability discrimination against employees, but the Court held that the Act’s antidiscrimination protections don’t extend to retired workers who no longer hold or desire a job at the time of the alleged discrimination.

Retired worker no longer ‘qualified’

The city of Sanford reduced health insurance benefits for its disabled retirees. At the time it did so, the city employed Karyn Stanley as a firefighter, and she wasn’t disabled.

Two years into her retirement, she filed an ADA employment discrimination claim against the city. But she didn’t specify when she became disabled, so the lower courts and the Supreme Court denied her ADA claim, finding she wasn’t a “qualified individual” under the meaning of the ADA and wasn’t entitled to receive ADA protections. Instead, the Supreme Court ruled that a “qualified individual” must be a current or prospective employee only.

Devil in the details

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