Former Employees Cannot Sue for ADA Discrimination in Benefits After Retirement

In June 2025, the Supreme Court ruled that the Americans with Disabilities Act (ADA) does not protect former employees from discrimination that occurs after they have retired or otherwise left the workforce. 

Decision: Stanley v. City of Sanford, 145 S. Ct. 2058 (2025)

Title I of ADA prohibits disability discrimination against a “qualified individual” in employment. A “qualified individual” is defined as someone who “can perform the essential functions of the employment position that such individual holds or desires.” 42 U.S.C. § 12111(8). The plaintiff, a former firefighter who retired due to Parkinson’s disease, alleged that the City of Sanford, Florida discriminated against her by offering her less health insurance benefits than those to other retirees. Stanley, 145 S. Ct. at 2063.

Holding: In an 8-1 decision, the Supreme Court held that to prevail under Title I of the ADA, a plaintiff must demonstrate that, at the time of the alleged discriminatory conduct, she held or desired a job and could perform all essential job functions. Id. at 2063-65. The Court ruled that the plaintiff, a retired individual who no longer sought employment, was not a “qualified individual” for purposes of Title I. Id. at 2065.

Justice Jackson, joined in part by Justice Sotomayor, dissented, warning that the majority “renders meaningless Title I protections for disabled workers retirement benefits just when those protections matter most.” Id. at 2090. Citing AARP’s amicus brief, she emphasized that retirement benefits are “a key factor in workers’ job-related decisions” and that protecting those benefits from disability discrimination is essential to fulfilling the ADA’s purpose of ensuring equal opportunity in all aspects of employment. Stanley, 145 S. Ct. at 2087 (Jackson, J., dissenting).

Implications

The Supreme Court’s decision effectively closes the door on ADA claims by former employees who experience disability-based discrimination in post-employment benefits, including health insurance or other retirement-related compensation. For workers who leave the workforce due to a disability—whether by choice or due to employment pressure—the ruling renders them ineligible to invoke Title I of the statute to challenge discriminatory treatment that emerges after their departure from the workforce.

Rachel N. Lokken, RLokken@aarp.org

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