Stanley v. City of Sanford

Majority reasoning

The majority held that the ADA's definition of "qualified individual" — someone who "can perform the essential functions of the employment position that such individual holds or desires" — uses present-tense verbs ("holds," "desires," "can perform") that signal the law protects only people who currently hold or seek a job at the time of the alleged discrimination. The Court reasoned that other parts of the statute, such as the definitions of "reasonable accommodation" (job restructuring, modifying facilities for employees) and the examples of discrimination in Section 12112(b) (qualification standards, employment tests), all make sense for current employees or job applicants but not for retirees. The majority also noted that Congress used broader language elsewhere in the ADA — protecting "any individual" from retaliation — which suggests the narrower "qualified individual" language in the employment discrimination provision was intentional. The Court rejected the argument that the ADA's broad purpose of eliminating disability discrimination requires extending Title I to retirees, reasoning that laws do not pursue their goals "at all costs" and that Congress, not the courts, is the proper body to expand the statute's reach. The majority also noted that other laws — including state law and the Rehabilitation Act — may still offer retirees avenues for relief.

Dissent reasoning

In dissent, Justice Jackson argued that the Court should not have used this case to announce a broad rule about post-retirement discrimination at all, because the facts of Lt. Stanley's complaint actually show she was subjected to the discriminatory policy while she was still employed and a "qualified individual" — making the sweeping ruling unnecessary and potentially an advisory opinion untethered to the actual facts. On the merits, the dissent argued that the "qualified individual" definition was never designed to act as a time limit on Title I's protections; rather, Congress inserted it solely to reassure employers that the ADA would not force them to hire or retain workers who cannot do the job. The dissent read the provision as a conditional mandate — if a plaintiff is seeking or holding a job, she must be able to perform its essential functions — but argued it says nothing about when discrimination must occur relative to one's employment. The dissent further argued that retirement benefits are deferred compensation earned during employment, so discriminating against a retiree in the payout of those benefits is, in effect, discriminating against that person in her capacity as a qualified employee who earned them. The dissent warned that the majority's rule produces arbitrary results — an employer who cuts disability-based retirement benefits one day before an employee retires faces liability, but the same employer faces none if it waits one day until after retirement.