606 U.S. 46
U.S.2025Background
- Karyn Stanley was hired as a Sanford, Florida firefighter in 1999; at hire the City promised retiree health insurance to age 65 for (a) those with 25 years’ service and (b) those who retired earlier because of disability.
- In 2003 the City revised its plan: only 25‑year retirees would get coverage to age 65; disability retirees would receive only 24 months (unless Medicare intervened).
- Stanley later developed a disability (diagnosed in the later record as Parkinson’s), retired for disability in 2018 after ~19 years, and received only the limited 24‑month coverage.
- She sued under Title I of the ADA alleging disability‑based discrimination in retirement benefits; the district court dismissed her ADA disparate‑treatment claim because the alleged harm occurred after retirement and she was not a “qualified individual” at that time; the Eleventh Circuit affirmed.
- The Supreme Court affirmed the Eleventh Circuit, holding that §12112(a) requires a plaintiff to have held or desired a job and been able to perform its essential functions (with or without reasonable accommodation) at the time of the employer’s discriminatory act; the Court also explained when claims based on earlier discriminatory adoption or application of a policy might proceed but declined to reach a merits ruling for Stanley because of pleading and preservation problems.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §12112(a) of the ADA reaches retirees who neither hold nor desire a job | Stanley: Title I protects any person alleging discrimination in compensation (retiree benefits), so the "qualified individual" term should not bar retirees | City: "Qualified individual" is defined with present‑tense verbs (holds or desires) and limits Title I to current applicants/employees | Court: §12112(a) requires plaintiff to be a qualified individual who holds or desires the position and can perform its essential functions at the time of the discriminatory act; retirees who neither hold nor desire the job are generally not covered under §12112(a) |
| Whether the statutory definition is best read as a conditional rule (applies only if plaintiff holds/seeks a job) or as a temporal limit | Stanley: If plaintiff neither holds nor desires a job, there are no essential functions to show and every retiree is thus "qualified" | City: Text and examples of reasonable accommodation and §12112(b) target applicants/employees, reflecting a present‑tense scope | Court: Rejected the conditional reading; present‑tense wording and contextual provisions show Congress tied protection to those holding or seeking jobs when discrimination occurs |
| Whether Stanley pleaded discrimination occurring while she was a qualified individual (timing/preservation) | Stanley / U.S. amicus: Record shows diagnosis before retirement; she was disabled and qualified during 2016–2018 and was subject to the discriminatory policy then | City / Eleventh Cir.: Complaint lacks timing details; Stanley disclaimed being "impacted" during employment and did not preserve the theory below | Court: Even accepting later factual developments, on the pleadings Stanley failed to allege the timing clearly and had forfeited the argument below; the Court therefore did not reverse on that theory but noted such claims may proceed when pleaded and preserved |
Key Cases Cited
- Cleveland v. Policy Management Systems Corp., 526 U.S. 795 (1999) (plaintiff must prove she was a "qualified individual" able to perform essential functions; assertions of inability to work can negate ADA claim)
- Robinson v. Shell Oil Co., 519 U.S. 337 (1997) (text and context can show whether statutory terms like "employee" encompass former employees)
- Hishon v. King & Spalding, 467 U.S. 69 (1984) (retirement benefits can constitute "compensation" or terms/conditions of employment)
- Davis v. Michigan Dept. of Treasury, 489 U.S. 803 (1989) (retirement benefits are deferred compensation for past service)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard: factual allegations must permit plausible inference of wrongdoing)
- Carr v. United States, 560 U.S. 438 (2010) (verb tense informs a statute's temporal reach)
- Burlington N. & S. F. R. Co. v. White, 548 U.S. 53 (2006) (‘‘discriminate against’’ means to treat worse; distinctions must injure protected individuals)
- Marx v. General Revenue Corp., 568 U.S. 371 (2013) (canon against surplusage is important but not absolute)
- Muldrow v. St. Louis, 601 U.S. 346 (2024) (using "discriminate against" to mean treat worse)