Supreme Court Considers Discrimination Case of Disabled Ex-Firefighter

On January 13, the U.S. Supreme Court reviewed the case of a retired Florida firefighter who suffers from Parkinson’s disease and has filed a discrimination lawsuit against her former employer regarding benefits after her retirement.

Karyn Stanley was forced to take early disability retirement at the age of 47 when her Parkinson’s disease advanced to a point where she could no longer fulfill her role as a firefighter for the city of Sanford, Florida.

Parkinson’s disease is a progressive neurological disorder that impacts the nervous system, leading to symptoms such as tremors, difficulties with walking and balance, and challenges in speech.

Stanley, whose lawsuit was paused by the lower courts, alleges that the city of Sanford discriminates against disabled retirees by imposing restrictions on their eligibility for health insurance subsidies.

She retired in 2018 after being employed by the city since 1999. At the onset of her employment, the city had a policy that provided insurance coverage until the age of 65 for employees retiring due to qualifying disabilities.

However, during Stanley’s tenure, the city revised its policy in 2003, capping coverage for disabled retirees at 24 months.

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In December 2021, the U.S. District Court for the Middle District of Florida ruled that former employees like Stanley lack the legal standing to file suits under the federal Americans with Disabilities Act (ADA), as they are deemed no longer “qualified individuals” protected against discrimination by the law.

Standing refers to the legal right to initiate a lawsuit, which requires a significant connection to the claim in order to justify involvement in court proceedings.

In October 2023, the U.S. Court of Appeals for the 11th Circuit sustained the lower court’s decision.

Title VII safeguards employees and job applicants from discrimination based on race, color, religion, sex, and national origin.

The ADA clearly states that employers are prohibited from “discriminating against a qualified individual on the basis of disability in relation to … terms, conditions, and privileges of employment.”

Nevertheless, federal appellate courts are divided over whether the anti-discrimination provisions of the ADA extend to disabled former employees seeking post-employment benefits, as noted in the petition.

During the oral arguments on January 13, Justice Ketanji Brown Jackson probed U.S. Department of Justice (DOJ) attorney Frederick Liu about whether he believed evidence of discrimination during Stanley’s employment should suffice for her case to proceed.

Liu affirmed, stating, “That should be enough.”

He added, “We believe that even if she couldn’t cite discrimination during her employment, she would still have a valid claim,” according to the DOJ attorney.

Stanley’s lawyer, Deepak Gupta, argued that the ADA protected his client when her employer rescinded her future benefits.

Justice Samuel Alito remarked that ADA cases generally focus on the issue of reasonable accommodation, typically relevant to current employees, not retirees.

He inquired, “How can the concept of reasonable accommodation relate to retirement benefits?”

“What constitutes discrimination here?” Alito questioned.

“How can a court differentiate between someone who has worked for 25 years and someone who retires due to a disability after a shorter period?”

The city’s attorney, Jessica Conner, contended that the ADA’s anti-discrimination provisions apply solely to current employees.

“Title I of the ADA forbids discrimination based on disability only against individuals who can perform the job they occupy or seek, in the present tense,” she stated.

Conner emphasized that the Eleventh Circuit was correct in ruling her Title I claim failed, as she could not demonstrate that the city discriminated against her “while she could perform the essential duties of a job she held or desired.”

“It is universally acknowledged” that an employer is not violating Title I when terminating an employee unable to perform the core responsibilities of their job, she commented.

“The result should be no different here simply because it involves retirees or post-employment benefits,” she continued.

Jackson asked Conner whether the city disputes that Stanley was disabled prior to her retirement.

Conner replied that it does not.

“The alleged discrimination occurred only when she was an unqualified individual after taking her retirement,” the attorney asserted.

Jackson asked, “How does one challenge discrimination regarding a policy affecting retirement and disability?”

Conner responded that the ADA’s language “clearly specifies whom it protects. It indicates that no employer shall discriminate against someone who can perform the job they hold or desire.”

Gupta contended that there are “at least two avenues” for Stanley to attain a legal victory.

“The narrow path is to assert that former employees may sue when alleging discrimination as qualified individuals during their employment,” he explained.

The broader route would be for the court to recognize that “former employees may contest post-employment discrimination.”

Conversely, the city urges the Supreme Court to determine that the “ADA’s safeguards for these benefits are least effective when they are needed most.”

“Congress did not create such a paradoxical framework,” remarked the attorney.

The Supreme Court is expected to deliver its decision in Stanley v. City of Sanford by the conclusion of June.