The US Supreme Court issued its opinion in Stanley v. City of Sanford, regarding disabled retired employees and whether there is a right to continuing health care benefits under the Americans with Disabilities Act, a federal statute. The ruling resolved a division between circuit courts on how to apply the Americans with Disabilities Act in certain circumstances. In Stanley v. City of Sanford, the Court determined that the Americans with Disabilities Act “ADA” generally applies only to disabled job applicants and disabled employees, but not to disabled retirees who are no longer employed and who do not desire a job. The Supreme court rejected the retiree’s Americans with Disabilities Act claim.
Title I of the Americans with Disabilities Act bars employers from discriminating against a qualified individual on the basis of disability in regard to compensation and other matters. 42 U.S.C.S. § 12112(a). Employment/Civil Rights Law. The statute defines a qualified individual as an individual who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires. 42 U.S.C.S. § 12111(8).
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If you are an employee who is experiencing discrimination, don’t sit on your rights. Contact us today for a free consultation. If you think you are being discriminated against because of your age, New Jersey Age Discrimination Lawyer, race, disability, sex, color, ethnic origin, religion, sexual orientation or other protected characteristic, you should contact this office today for a free consultation.
To prevail in a discrimination claim brought under the ADA, the person must prove she is a “qualified individual” under the ADA. To prevail as a “qualified individual” under the ADA, a plaintiff must plead and prove that she held or desired a job, and could perform the essential functions of the job with or without reasonable accommodation at the time of an employer’s alleged act of disability-based discrimination.
NOTE: The US Supreme Court’s ruling separated and addressed claims only brought under the ADA regarding disabled retired employees and continuing health care benefits, from several other types of employment claims regarding continuing various benefits, such as the Employee Retirement Income Security Act of 1974 (ERISA). This article only addresses the Court’s decision as to the federal statute, the Americans with Disabilities Act, 42 U.S.C. § 12101 et seq. It does not address whether a retired individual with a disability is entitled to continuing health benefits under other state discrimination or federal statutes. These benefits may be governed by other federal statutes, and by individual state statutes including state pension statutes, private employer plan policies, and collective bargaining agreements. See NJ Employment Lawyer, Disabled Employee and Hostile Work Environment.
The US Supreme Court in its 8-1 decision on June 20, 2025, held in Stanley v. City of Sanford that a retired employee who does not hold or seek a job is not a qualified individual under the Americans with Disabilities Act because to prevail under 42 U.S.C.S. § 12112(a), a plaintiff must plead and prove that she held or desired a job, and could perform its essential functions with or without reasonable accommodation at the time of an employer’s alleged act of disability-based discrimination. The Court held that the Americans with Disabilities Act’s Section 12112(a) protects people, not benefits, from discrimination and that 42 U.S.C.S. § 12111(8) defines who are qualified individuals under the Americans with Disabilities Act: qualified individuals are those who hold or seek a job at the time of the defendant’s alleged discrimination.
The Supreme Court upheld the Circuit Court’s dismissal of a firefighter's ADA complaint against her former employer, the City of Sanford. The Court held that the dismissal was proper since the reduction of her healthcare benefits did not take place until after she retired early due to disability, at which time she was no longer a “qualified individual” under the ADA.
If you resign, you may lose right to prevail in a lawsuit. New Jersey Disability Discrimination Lawyer. In many instances of discrimination and retaliation, if you resign, you may lose right to prevail in a lawsuit unless you first take certain legally required measures to preserve your job while you are still employed. If you are thinking of resigning, or think you will be fired, or have been fired, you should contact this office immediately for a free consultation to discuss your options in the safest way for you. New Jersey Employment Unlawful Retaliation Attorney.
The ADA bars employers from discriminating against a qualified individual on the basis of disability in regard to compensation and other matters. 42 U.S.C.S. § 12112(a). The statute defines a qualified individual as an individual who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires. 42 U.S.C.S. § 12111(8).
See NJ Employment Attorney, Employer Discriminates When Boss Says You’re Not Qualified Because of Your Sex, Age, Race, or Disability.
NOTE: This article is not legal advice, and is not to be construed as giving legal advice, nor be relied upon as legal advice in any situation or case. There are numerous changes and amendments in discrimination law and employment law that are mandated every year. If you have a legal question, you should consult with an employment attorney to discuss the specifics of your situation.
See NJ Employment Attorney, Employee Managers Requiring Disability Accommodation Pressured into Resigning.
What You Can Do.
I have represented employees who were illegally discriminated against by their employers, and was successful in recovering financial compensation for their emotional pain and suffering and moneys for lost wages, both for past lost wages and projected future lost wages. If you think you are being discriminated against, you should contact this office immediately for a free consultation. I accept discrimination and whistleblower cases from all over New Jersey and have locations in Southern, Central and Northern NJ to meet with clients.
Contact Hope A. Lang, Attorney at Law today for a free consultation.
Hope A. Lang, Attorney at Law represents workers throughout the entire state, including Hackensack, Jersey City, Newark, Irvington, Orange, East Orange, Trenton, Paterson, Montclair, Elizabeth, North Brunswick, Cherry Hill, Vineland, Union, Plainfield, Hamilton Township, Lakewood, Edison, Parsippany-Troy Hills, Franklin, Lakewood, and every NJ County, including Bergen, Hudson, Middlesex, Essex, Monmouth, Somerset, Ocean, Union, Camden, Passaic, Morris, Gloucester, Atlantic, Burlington, Camden Counties.