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Stanley v. City of Sanford, Florida

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Supreme Court of the United States
Stanley v. City of Sanford, Florida
Term: 2024
Important Dates
Argued: January 13, 2025
Decided: June 20, 2025
Outcome
affirmed
Vote
8-1
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett
Concurring
Clarence Thomas (in part) • Amy Coney Barrett (in part) • Sonia Sotomayor (in part)
Dissenting
Ketanji Brown Jackson • Clarence Thomas (in part) • Amy Coney Barrett (in part) • Sonia Sotomayor (in part)

Stanley v. City of Sanford, Florida is a case that was decided by the Supreme Court of the United States on June 20, 2025, during the court's October 2024-2025 term. The case was argued before the Supreme Court of the United States on January 13, 2025.

In a 8-1 opinion, the court affirmed the judgment of the United States Court of Appeals for the Eleventh Circuit. The court held that to prevail under 42 U. S. C. §12112(a), a plaintiff has to plead and prove that they held or desired a job, and could perform its essential functions with or without reasonable accommodation, at the time of an employer’s alleged act of disability-based discrimination. A number of suits involving retirement benefits might apply under this rule. However, due to how this case came to the Supreme Court, the court could not say that the Eleventh Circuit erred in affirming the dismissal of Ms. Stanley’s complaint. Justice Neil Gorsuch delivered the opinion of the court.[1]

HIGHLIGHTS
  • The issue: The case concerned qualifying for retirement benefits under the Americans with Disabilities Act (ADA). Click here to learn more about the case's background.
  • The questions presented: "Under the Americans with Disabilities Act, does a former employee—who was qualified to perform her job and who earned post-employment benefits while employed—lose her right to sue over discrimination with respect to those benefits solely because she no longer holds her job?"[2]
  • The outcome: In a 8-1 opinion, the court affirmed the judgment of the United States Court of Appeals for the Eleventh Circuit.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the Eleventh Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    Background

    Karyn D. Stanley is a retired firefighter with the Sanford, Florida fire department. She was forced to take disability retirement as a result of her Parkinson’s Disease. When she first joined the department in 1999, the city's employee benefits plan policy was such that employees taking disability retirement were entitled to free health insurance until they were 65 years old. In 2003, the city changed its benefits plan so that disability retirees received the free health insurance for 24 months after retiring. As of December 1, 2020, Stanley would be responsible for paying for her health insurance.[3][4][5]

    In April 2020, she sued the city in the United States District Court for the Middle District of Florida in order to receive the original, longer-term benefit plan. She asserted that the city's benefits plan change discriminated against disabled retirees under the Americans with Disabilities Act (ADA) and the equal protection clause. The district court dismissed her claims and granted summary judgment in favor of the city.[3][4]

    On appeal, a three-judge panel of the United States Court of Appeals for the Eleventh Circuit affirmed the district court, holding:[3]

    “ Can a former employee sue under Title I of the Americans with Disabilities Act for discrimination in post-employment distribution of fringe benefits? We answered "no" in Gonzales v. Garner Food Services, Inc., 89 F.3d 1523 (11th Cir. 1996). Gonzales put us at odds with the Second and Third Circuits but in league with the Sixth, Seventh, and Ninth Circuits. In this appeal, we must decide whether Gonzales is still good law after (1) the Supreme Court's decision about Title VII retaliation in Robinson v. Shell Oil Co., 519 U.S. 337, 117 S.Ct. 843, 136 L.Ed.2d 808 (1997), and (2) Congress's changes to the text of the ADA.


    We believe Gonzales is still good law. We thus reaffirm that a Title I plaintiff must "hold[ ] or desire[ ]" an employment position with the defendant at the time of the defendant's allegedly wrongful act. 42 U.S.C. § 12111(8). Because plaintiff Karyn Stanley is suing over the termination of retirement benefits when she neither held nor desired to hold an employment position with her former employer, the City of Sanford, Gonzales bars her claim. We therefore affirm the district court.[6]

    		”


    On March 8, 2024, Karyn D. Stanley filed a writ of certiorari, asking the U.S. Supreme Court to review the case and dispose the circuit split regarding whether former employees qualify for ADA benefits.[4]

    On June 24, 2024, SCOTUS accepted the case to its merits docket for October Term 2024.


    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Under the Americans with Disabilities Act, does a former employee—who was qualified to perform her job and who earned post-employment benefits while employed—lose her right to sue over discrimination with respect to those benefits solely because she no longer holds her job?[6] ”

    Oral argument

    Audio

    Audio of oral argument:[7]




    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a 8-1 opinion, the court affirmed the judgment of the United States Court of Appeals for the Eleventh Circuit. The court held that to prevail under 42 U. S. C. §12112(a), a plaintiff has to plead and prove that they held or desired a job, and could perform its essential functions with or without reasonable accommodation, at the time of an employer’s alleged act of disability-based discrimination. A number of suits involving retirement benefits might apply under this rule. However, due to how this case came to the Supreme Court, the court could not say that the Eleventh Circuit erred in affirming the dismissal of Ms. Stanley’s complaint. Justice Neil Gorsuch delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Neil Gorsuch wrote:[1]

    “

    The trouble for Ms. Stanley is that §12112(a) does not prohibit disability-based discrimination in the abstract. Instead, it bars an employer from ‘discriminat[ing] against a qualified individual on the basis of disability.’ (Emphasis added.) ‘‘Discriminate against’ means treat worse,’ Muldrow v. St. Louis, 601 U. S. 346, 355 (2024), and ‘refers to distinctions or differences in treatment that injure protected individuals,’ Burlington N. & S. F. R. Co. v. White, 548 U. S. 53, 59 (2006). And Ms. Stanley’s complaint provides no basis for inferring that the City’s policy injured her in 2003. To the contrary, her complaint suggests that, when the City first issued its policy, she was not disabled and still expected to complete 25 years of service. See Complaint ¶15; see also Brief for Appellant in No. 22–10002 (CA11), p. 22, n. 5 (Ms. Stanley representing that she was ‘unaffected by’ the City’s actions as of 2003). So the first option is off the table for Ms. Stanley. Even so, it may be available to others who happen to be retired at the time they sue, if they can plead and prove they were both disabled and ‘qualified’ when their employer adopted a discriminatory retirement-benefits policy.[6]

    		”
    —Justice Neil Gorsuch

    Concurring in part, Dissenting in part opinion

    Justice Thomas

    Justice Clarence Thomas filed an opinion concurring in part and dissenting in part, joined by Justice Amy Coney Barrett.

    In his opinion, Justice Thomas wrote:[1]

    “

    I join Parts I and II of the Court’s opinion. I write separately to express my concern with the increasingly common practice of litigants urging this Court to grant certiorari to resolve one question, and then, after we do so, pivoting to an entirely different question. This case exemplifies the problem. We granted review to resolve a Circuit split regarding whether the Americans with Disabilities Act (ADA) permits suits by former employees who are no longer able to perform the essential functions of their jobs at the time of the alleged discrimination. For the first time at the merits stage, petitioner Karyn Stanley urged us to decide a different question: whether Stanley could sue based on discrimination that occurred while she was still employed and able to work. But, that theory of liability was not passed upon below because the Eleventh Circuit determined that Stanley had disavowed it, and Stanley did not seek review of the Eleventh Circuit’s issue-preservation ruling. We ordinarily respect a lower court’s application of its own preservation rules. I therefore would not opine on the additional question that Stanley raised for the first time in earnest at the merits stage.[6]

    		”
    —Justice Clarence Thomas

    Justice Sotomayor

    Justice Sonia Sotomayor filed an opinion concurring in part and dissenting in part.

    In her opinion, Justice Sotomayor wrote:[1]

    “

    There is good reason to think that Stanley herself was subject to the allegedly discriminatory policy at issue here while she was both disabled and employed. See ante, at 14 (plurality opinion); post, at 5 (JACKSON, J., dissenting). Yet I ultimately agree with the plurality that this theory ‘cannot form a basis for reversing the Eleventh Circuit’s judgment in this particular case,’ ante, at 15, especially because Stanley herself did not ask this Court to review the Eleventh Circuit’s holding that she had forfeited this theory before that court, ante, at 15–16 (plurality opinion). Because Part III nevertheless makes clear that Title I may well provide relief for retirees like Stanley, I join that portion of JUSTICE GORSUCH’s opinion.[6]

    		”
    —Justice Sonia Sotomayor

    Dissenting opinion

    Justice Ketanji Brown Jackson filed a dissenting opinion, joined by Justice Sonia Sotomayor as to Parts III and IV, except for footnote 12.

    In her dissent, Justice Jackson wrote:[1]

    “

    Disabled Americans who have retired from the workforce simply want to enjoy the fruits of their labor free from discrimination. Congress plainly protected their right to do so when it crafted Title I. Yet, the Court ignores that right today. It reaches out to cut off postemployment protection against disability discrimination in a case that does not require us to decide that question; seizes upon the inapposite text of the qualified-individual definition; and converts that text into a temporal limit it was never designed to be. Worse still, by doing all this, the Court renders meaningless Title I’s protections for disabled workers’ retirement benefits just when those protections matter most.

    It is lamentable that this Court so diminishes disability rights that the People (through their elected representatives) established more than three decades ago. Even so, there is hope for a legislative intervention to fix the mistake the Court has made. Americans with disabilities have proven time and again that they can overcome long odds in fighting for their own equality. When that happens, my one wish would be for this Court to stay out of their way.[6]

    		”
    —Justice Ketanji Brown Jackson

    Text of the opinion

    Read the full opinion here.

    October term 2024-2025

    See also: Supreme Court cases, October term 2024-2025

    The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 1.7 U.S. Supreme Court, "Stanley v. City of Sanford, Florida," June 20, 2025
    2. ↑ 2.0 2.1 U.S. Supreme Court, "23-997 STANLEY V. CITY OF SANFORD, FLORIDA," June 24, 2024
    3. ↑ 3.0 3.1 3.2 3.3 U.S. Court of Appeals for the Eleventh Circuit, Stanley v. City of Sanford, Fla., decided October 11, 2023
    4. ↑ 4.0 4.1 4.2 U.S. Supreme Court, "Stanley v. City of Sanford, Florida PETITION FOR A WRIT OF CERTIORARI," filed March 8, 2024
    5. ↑ SCOTUSblog, "Nine new relists as the court approaches the finish line," June 20, 2024
    6. ↑ 6.0 6.1 6.2 6.3 6.4 6.5 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ [https://www.supremecourt.gov/oral_arguments/audio/2024/23-997 Supreme Court of the United States, "Oral Argument - Audio," argued January 13, 2025 ]
    8. ↑ [https://www.supremecourt.gov/oral_arguments/argument_transcripts/2024/23-997_6468.pdf Supreme Court of the United States, "Oral Argument - Transcript," argued January 13, 2025 ]
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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