Karyn D. Stanley v. City of Sanford, Florida, 83 F.4th 1333

Background

Karyn Stanley was a Sanford, Florida firefighter diagnosed with Parkinson’s in 2016 and took disability retirement effective November 1, 2018.
The City changed its benefits plan in 2003 (unknown to Stanley) so disability retirees receive a health-insurance subsidy for 24 months after retirement rather than until age 65; Stanley was set to begin paying premiums on December 1, 2020.
Stanley sued in April 2020 under Title I of the ADA, the Rehabilitation Act, the Florida Civil Rights Act, the Equal Protection Clause, and Fla. Stat. §112.0801, seeking continuation of the long‑term subsidy.
The district court dismissed Stanley’s disability discrimination claims, relying on Gonzales v. Garner Food Services, and granted summary judgment to the City on the Equal Protection and §112.0801 claims.
On appeal the Eleventh Circuit considered whether Gonzales remains binding after Robinson v. Shell Oil and statutory amendments (ADAAA and the Fair Pay Act), and whether Stanley was a "qualified individual" at the time of the alleged discriminatory act.
The panel affirmed: Gonzales remains binding; Stanley was not a qualified individual at the time of the post‑employment benefit termination; Equal Protection and statutory claims fail.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a former employee can sue under Title I for post‑employment discrimination in fringe benefits	Stanley: Robinson undermines Gonzales; Title I should cover former employees for post‑employment discrimination	City: Gonzales controls; Title I protects only those who "hold or desire" an employment position when discrimination occurred	Gonzales remains binding; Title I requires plaintiff to hold or desire a job at the time of the discriminatory act; former employees cannot sue for post‑employment benefits discrimination
Whether Robinson v. Shell Oil abrogated Gonzales	Stanley: Robinson’s holding on post‑employment retaliation makes Gonzales obsolete	City: Robinson addressed Title VII retaliation and did not alter Title I’s unambiguous temporal language	Robinson did not overrule Gonzales; it was not clearly on point for Title I
Whether post‑enactment statutes (ADAAA, Fair Pay Act) overrule Gonzales	Stanley: Congress broadened ADA protections, so Gonzales should not bind now	City: ADAAA left the "qualified individual" definition’s temporal phrasing intact; Fair Pay Act altered accrual rules but not substantive Title I requirements	Amendments do not clearly change the statutory text relied on in Gonzales; Gonzales survives
Whether Stanley’s Equal Protection and Fla. Stat. §112.0801 claims succeed	Stanley: The benefits change discriminated against disabled retirees and the City should have continued paying premiums	City: Benefit change is rationally related to conserving funds; §112.0801 only requires the option to continue coverage, not free premiums	Summary judgment for City; rational‑basis review satisfied; statute permits employer discretion on premium payment

Key Cases Cited

Gonzales v. Garner Food Servs., Inc., 89 F.3d 1523 (11th Cir. 1996) (held former employees cannot sue under Title I for post‑employment fringe benefits)
Robinson v. Shell Oil Co., 519 U.S. 337 (1997) (Title VII covers post‑employment retaliation)
Johnson v. K Mart Corp., 273 F.3d 1035 (11th Cir. 2001) (panel concluded Gonzales overruled; decision later vacated en banc)
McKnight v. Gen. Motors Corp., 550 F.3d 519 (6th Cir. 2008) (holds Title I does not cover former employees)
Weyer v. Twentieth Century Fox Film Corp., 198 F.3d 1104 (9th Cir. 2000) (same)
Castellano v. City of New York, 142 F.3d 58 (2d Cir. 1998) (reads Title I ambiguously and extends protection to former employees)
Ford v. Schering‑Plough Corp., 145 F.3d 601 (3d Cir. 1998) (similar to Castellano)
City of Cleburne v. Cleburne Living Ctr., 473 U.S. 432 (1985) (establishes rational‑basis review for non‑suspect classes)
Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (2007) (pre‑Fair Pay Act accrual rule for pay discrimination)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading‑standard precedent)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading‑standard precedent)