The ADA on Trial: What Stanley v. City of Sanford Reveals About Disability Rights Today
2025 | Haley Zavsza (Associate Editor)
Introduction
Across the nation, millions of public employees are under the impression that secure healthcare is a part of their retirement benefits. However, policies often change without employees being adequately informed, leaving many unaware of the changes until it is too late. In the case of Karyn Stanley, this reality became painfully clear. Stanley, a firefighter for the City of Sanford, Florida (Sanford), retired after 19 years of service because of a disability in 2018. Thinking she was guaranteed health insurance until age 65, free of cost, the truth became apparent when she realized she was only covered for 2 years. Since then, Sanford altered the policy and limited the health insurance subsidy for retirees with disabilities. Once brought to the district court, Stanley’s case was dismissed because her claim under the Americans with Disabilities Act (ADA) was deemed invalid, as she was no longer employed at the time of the incident.[1] Stanley brought the case to the Supreme Court on January 13, 2025. The decision raised an important question: If the ADA does not protect the rights of disabled employees, what does? The interpretation of the Stanley v. City of Sanford, Florida case highlights issues within the Americans with Disabilities Act, and the act should be altered to include retired employees.
Alleged Violations
According to Stanley, the limitation of the health insurance subsidy for disability retirees allegedly violates the Americans with Disabilities Act, the Rehabilitation Act, the Florida Civil Rights Act, the Equal Protection Clause, and Florida Statutes §112.081.[2] Each law establishes protections of rights and equal opportunities for individuals with disabilities, which Sanford purportedly failed to protect.
The Equal Protection Clause, part of the 14th Amendment (14.§1.8.1.6), ensures that no state can enact or enforce laws that abridge the privileges or immunities of U.S. citizens.[3] Additionally, the clause mandates that no state deny any person within its jurisdiction the equal protection of the laws. 14.§1.8.1.6 provided a foundational framework for the equal treatment of individuals, eventually playing a significant role in the development of disability rights later on.
Modeled after the Civil Rights Act, a historic shift in anti-discriminatory disability public policy occurred with the passage of §504 in the Rehabilitation Act of 1973.[4] 29 U.S.C. §794 of the Rehabilitation Act of 1973 bans discrimination based on disability by recipients under any program/activity receiving federal financial assistance, any executive agency, or by the United States Postal Service.[5] Considering that a fire department operates as an executive agency, Stanley’s case is subject to the nondiscrimination requirements in §504.
The Americans with Disabilities Act (ADA) of 1990 further expanded upon the Rehabilitation Act’s protections, prohibiting discrimination based on disability in various aspects of public life, including employment, public services, public transportation, and overall societal participation.[6] 42 U.S.C. §12112 prohibits discrimination by a covered entity against any qualified individual with a disability in job application procedures, hiring, termination, compensation, advancement, training, and terms of employment.[7] “Covered entities” include employers, employment agencies, labor organizations, or joint labor-management committees. The term “qualified individual” refers to an individual who, with or without reasonable accommodation, can perform the essential functions of the employment position the individual holds or desires.[8]
The Florida Civil Rights Act (FCRA) of 1992 was enacted shortly after the ADA was instituted.[9] §760.10a illustrates unlawful employment practices under the law, which are the termination, refusal to hire, or discrimination against any individual for compensation, terms, conditions, or privileges of employment because of such attributes of secured freedoms.[10]
Florida Statutes §112.0801(1) requires that any public employer offering group or self-insurance must offer retirees and their eligible dependents the same health and hospitalization insurance coverage as active employees and no more than the premium cost of active employees.[11] §112.0801(1) is significant because it directly supports Stanley’s argument that retirees should not be excluded from the protections and benefits offered to active employees. Thus, the statute highlights a contradiction, as the state law ensures equality in insurance coverage, but the Stanley v. City of Sanford case denies this under the ADA.
Stanley v. City of Sanford Case Facts
Stanley v. City of Sanford, Florida, is a pending Supreme Court case involving the petitioner, Karyn Stanley, and the respondent, the City of Sanford, Florida.[12] When Stanley joined the firefighter force in 1999, the city’s policy provided free health insurance until age 65 for employees who retired due to disability. However, the city reduced the health insurance subsidy for disability retirees, which once lasted until age 65, to merely 24 months after retirement in 2003. Now, an individual must complete 25 years of service to qualify for health insurance coverage until age 65. Unaware of this change, Stanley retired in 2018 after serving 19 years due to the manifestation of Parkinson’s disease. Stanley filed suit in April 2020, before the subsidy expired, alleging violations of the Americans with Disabilities Act, the Rehabilitation Act, the Florida Civil Rights Act, the Equal Protection Clause, and Florida Statutes §112.0801. The district court dismissed all claims in favor of the city with affirmation from the U.S. Court of Appeals for the Eleventh Circuit, since, according to 42 U.S.C. §12112, Stanley must be employed at the time of the supposed wrongful act.[13] Unable to argue her case, Stanley brought the case to the Supreme Court on January 13, 2025, and awaits a decision on whether the ADA is applicable.
Stanley vs. Eleventh Circuit’s Arguments
The main dispute between Stanley and the Eleventh Circuit centers on the definition section of the ADA, specifically the term “qualified individual.” The statute held that a qualified individual is someone who, with or without reasonable accommodation, can perform the essential functions of the employment position that such an individual holds or desires.
The Eleventh Circuit based its decision on the outcome of Gonzales v. Garner Food Services, Inc.(Gonzales), which ruled that a former employee who does not hold or desire an employment position cannot sue over discriminatory post-employment benefits.[14] Following the prior-panel-precedent rule to address the conflict, the court concluded that Stanley had retired, dismissing the case as it did not fall under the ADA.
However, Stanley combated the decision by arguing that Gonzales did not ban her claim. The case of Gonzales was decided in the context of someone acting on behalf of another. August Gonzales, the administrator of Timothy Bourgeois’s estate, filed the lawsuit on Bourgeois’s behalf after he passed away. Since Gonzales was not employed, he could not file suit based on discrimination. Additionally, the 2001 Johnson v. K Mart Corp. (Johnson) addressed the same question in Gonzales: “Can a former employee file suit against a former employer?” The majority in Johnson took into account the Supreme Court’s decision in Robinson v. Shell Oil Co. (Robinson), which ruled that an individual could sue his or her former employer under Title VII for the post-employment retaliatory act.[15] The Johnson court viewed the decision in Robinson as significant, holding that Title I of the ADA prohibits discriminatory acts against current and former employees. However, the ruling was removed during the rehearing of the case. As a result, the center of Stanley’s argument is to resurrect the former Johnson ruling and hold that, after the Robinson decision, former employees can sue under Title I of the ADA for post-employment discrimination.
Conclusion
The case of Stanley v. City of Sanford, Florida, raises the question of whether former employees have the right to file a discrimination claim when they retire. If the Supreme Court favors Sanford, disabled former employees will be unable to sue for post-retirement benefits based on discrimination. Although backed by previous cases such as Gonzales, the possible decision would highlight a need for alteration within the ADA. Retired disabled employees should have the same rights as current employees, especially if they are receiving post-retirement benefits. Even though laws prohibiting discrimination based on disability have progressed over time, there is still room for change, which is needed to protect the rights of former disabled employees.
Sources
“Stanley v. City of Sanford, Florida.” n.d. Oyez.
Ibid.
Library of Congress. n.d. “Amdt14.S1.8.1.6 Public Accommodations and Facially Non-Neutral Laws.” Congress.gov.
U.S. Department of Labor. n.d. “Section 504, Rehabilitation Act of 1973.” Office of the Assistant Secretary for Administration & Management.
Ibid.
Library of Congress. n.d. “S.933 - 101st Congress (1989-1990): Americans with Disabilities Act of 1990.” Congress.gov.
Ibid.
U.S. Department of Justice. n.d. “Americans with Disabilities Act of 1990, As Amended.” ADA.gov.
The Florida Senate. n.d. “2011 Florida Statutes.” FLHouse.gov.
Ibid.
The Florida Senate. n.d. “2011 Florida Statutes.” FLHouse.gov.
Ibid.
Ibid.
“Karyn D. Stanley v. City of Sanford, Florida, No. 22-10002 (11th Cir. 2023).” 2023. Justia Law.
Ibid.
