In America: Supreme Court Weighs Disability Protections for Retirees in Landmark Case for Ex-Firefighter
Earlier this month, the United States Supreme Court heard arguments and is poised to issue a ruling in Karyn Stanley v. The City of Sanford, FL. The court’s ruling will set an important precedent for years to come. It could redefine employer liability as it pertains to the Americans with Disabilities Act (ADA) for those ailments that are diagnosed while a person is still employed. In the case of Karyn Stanley, a former firefighter from Florida, the disease in question is Parkinson’s, a progressive brain disorder that affects movement. There is no known cure for this disease.
The Case at a Glance
Karyn Stanley served The City of Sanford, just outside Orlando, for nearly two decades before Parkinson’s forced her to retire at age 47. Under the City’s old regulations, it provided health insurance subsidies to retirees. However, in 2003, most likely due to budgetary constraints, Sanford changed its policy. Per the new guidelines, employees retiring after 25 years of service would have subsidized health insurance until 65, when they became eligible for Medicare. Yet, those who retired due to disability, like Stanley, would only have 2 years of subsidized healthcare.
Stanley’s legal team argues that this policy violates the ADA, which prohibits discrimination against individuals with disabilities in “compensation” and “other terms, conditions, and privileges of employment,” including fringe benefits. The city, however, contends that the ADA does not apply to former employees and that Stanley lacks standing to sue because she was no longer employed when the alleged discrimination occurred.
At the heart of the case is a simple question – must employers continue to cover health insurance for retirees whose disabilities were identified while they were still working? The decision, expected this summer, could have far-reaching implications for employers and employees nationwide. This sentiment is echoed by the plaintiff, who said, “I’m seeking justice not only for me but also for countless disabled firefighters and other disabled workers across the country.”
During oral arguments, the justices appeared divided. Some expressed sympathy for Stanley’s plight, while others questioned the legal basis for her claims.
Stanley’s Argument & Evidence –
Karyn Stanley’s attorney, Deepak Gupta, spoke of two assertions for the bench's consideration when deciding on the case’s outcome. The first, and narrower argument presented by Mr. Gupta argues that between Ms. Stanley’s diagnosis in 2016, and her eventual retirement in 2018, she was subjected to discrimination by the City, which meant lower financial compensation due to alleged discriminatory policies.
The second and broader argument is that the ADA should protect former employees from discrimination even if they are retired. Mr. Gupta emphasized that without protections for their retirement, the ADA’s protection of retirement benefits is rendered useless. “The ADA’s protection for these benefits would mean the least when they matter the most,” he told the justices.
Frederick Liu, an assistant to the U.S. solicitor general, echoed Mr. Gupta’s narrower argument, stating that the “most straightforward path” for Stanley’s lawsuit to proceed lies in the period after her diagnosis but before her retirement.
The City’s Rebuttal
Ms. Jessica Conner, who represents the City of Sanford, implored the Justices to hold up the decision made by the lower courts. The US Court of Appeals for the Eleventh Circuit ruled that Stanley had no legal standing to sue the city under the ADA as she was not employed when she alleged the discrimination transpired. Ms. Conner argued that the act protected “current employees,” and “applicants,” not retirees.
She also warned that taking the measure to protect all previous employees could open a “floodgate,” of litigation and impose an excessive burden on employers, be they a city or otherwise. “The court of appeals was correct when it held that Stanley’s claim could not go forward because she could not show that the city discriminated against her while she could perform the essential functions of a job that she held or desired to hold,” Conner said.
The Justices’ perspectives
Appointed in 1991 by Republican President George H.W. Bush, Justice Clarence Thomas, one of the conservative voices in the court questioned the lower courts. He asked if the court for the Eleventh Circuit sufficiently spoke to Stanley’s primary argument of alleged discrimination. “Did the courts below decide your first point?” he asked.
Justice Elena Kagan, appointed by President Barack Obama in 2010 is on the opposite side of the political spectrum from Justice Thomas. She was skeptical about the broader question of expanding protections but signaled legitimacy to the narrower claims of discrimination. “And it seems a little bit odd to decide this bigger, broader question that you would like us to decide…” she said, emphasizing that if a verdict could be reached based on the narrower arguments, that would take priority, rather than changing the law to include all past employees.
Justice Samuel Alito, appointed in 2006 by President George W. Bush and a conservative, raised concerns about how courts would navigate the complexities of ADA claims involving retirement benefits. He questioned how to determine whether distinctions between employees who retire after 25 years and those who retire earlier due to disability are lawful. He contested, “How are courts supposed to decide these questions under the ADA?” he continued, 'I want to know where we’re going with this'”.
This sentiment was challenged by Justice Ketanji Brown Jackson, appointed by President Joe Biden in 2022, another liberal voice on the bench. She and Kagan expressed concern that under the city’s rule, retirees would never be able to challenge discrimination related to retirement benefits. “Isn't this a different scenario as well -- you said this was a different scenario in terms of the Eleventh Circuit's waiver argument -- because we're talking about fundamentally a motion to dismiss and whether or not Ms. Stanley plausibly alleged discrimination,” Jackson noted.
The Ruling’s Potential Implications
The Supreme Court’s decision in Stanley v. Sanford holds immense potential implications for employers and employees nationwide. A ruling in favor of Stanley could extend the Americans with Disabilities Act (ADA) to encompass post-employment benefits, ensuring that retirees with disabilities don’t jeopardize crucial health insurance subsidies.
Conversely, a decision favoring the city could narrow the scope of the ADA, leaving retirees vulnerable to discriminatory policies. Employers are vigilantly tracking the case, as a ruling against the city could lead to increased liability and administrative burdens.
This case is part of a broader debate about the extent of the ADA and its protections for individuals with disabilities. The ADA, enacted in 1990, was intended to provide comprehensive protections against discrimination in employment, public services, and accommodations. However, its application for post-employment benefits has been a contentious issue, with lower courts divided on the matter.
The Constitutional Accountability Center, a non-profit think tank, filed an amicus brief in support of Stanley, arguing that the Eleventh Circuit’s decision contradicts the text and historical context of the ADA. The brief emphasizes that Congress intended the ADA to provide robust protections for individuals with disabilities, including during the post-employment period.
What Comes Next?
The Supreme Court is expected to issue its decision by summer 2024. Regardless of the outcome, the case will likely establish a precedent for how employers administer retirement benefits and how the ADA is interpreted in the context of post-employment discrimination.
For Karyn Stanley, the decision will determine whether she can continue her fight for justice. For employers and employees across the country, it will shape the future of disability rights in the workplace.