The question
Whether a retired employee who neither holds nor desires a job is a "qualified individual" who can sue for disability discrimination in compensation under Title I of the Americans with Disabilities Act, 42 U.S.C. section 12112(a).
Stanley v. City of Sanford
What the Court decided
The Court affirmed the Eleventh Circuit, ending Karyn Stanley's ADA claim against the City of Sanford. To sue under section 12112(a), a plaintiff must plead and prove that she held or desired a job whose essential functions she could perform, with or without reasonable accommodation, at the time of the employer's alleged discrimination. A retiree who neither holds nor seeks a job at that time is not a "qualified individual" and cannot bring a Title I disparate-treatment claim, even when the challenged benefit counts as compensation.
How the justices split
7-2The Court's opinion in part
Gorsuch, joined by Roberts, Thomas, Alito, Kagan, Kavanaugh, Barrett
Parts I and II are the opinion of the Court. Section 12112(a) protects a qualified individual, defined by present-tense verbs as someone who holds or desires a job and can perform its essential functions with or without reasonable accommodation. That language protects current job holders and applicants at the time they suffer discrimination, not retirees who neither hold nor seek a job. The statutory definitions of reasonable accommodation and the examples of prohibited discrimination fit current employees and applicants, and comparison to Title VII of the Civil Rights Act and the Court's decision in Cleveland v. Policy Management Systems Corporation confirm this reading. The Court rejected Stanley's contrary interpretations, including her surplusage and statutory-purpose arguments, and noted that Congress may extend Title I to retirees if it chooses.
The plurality in part
Gorsuch, joined by Alito, Sotomayor, Kagan
Part III is an opinion of Gorsuch joined by three justices and does not command a majority. The syllabus does not set out its reasoning.
Concurring in part and in the judgment
Thomas, joined by Barrett
Thomas concurred in part and concurred in the judgment. He agreed with the outcome affirming dismissal and joined Parts I and II, writing separately on grounds the syllabus does not detail.
Dissenting in part
Sotomayor, writing alone
Sotomayor concurred in part and dissented in part. She joined the Court's opinion as to Part III and joined Jackson's dissent as to Parts III and IV except for a footnote, agreeing with the majority in part while disagreeing with other parts of the disposition. The syllabus does not set out her reasoning.
Dissenting
Jackson, joined by Sotomayor
Jackson dissented, joined by Sotomayor as to Parts III and IV except for one footnote. She disagreed with the Court's conclusion that section 12112(a) does not reach discrimination against retirees like Stanley. The syllabus does not set out her reasoning.
How we know · 5 sourced claims
The Court affirmed the Eleventh Circuit's judgment, reported at 83 F.4th 1333.
Source: syllabus, Held
To prevail under section 12112(a), a plaintiff must plead and prove she held or desired a job and could perform its essential functions, with or without reasonable accommodation, at the time of the alleged discrimination.
Source: syllabus, Held
A retiree who neither holds nor desires a job is not a qualified individual under Title I of the ADA, because the definition in section 12111(8) uses present-tense verbs.
Source: syllabus, Held
Gorsuch delivered the opinion of the Court as to Parts I and II, joined by Roberts, Thomas, Alito, Kagan, Kavanaugh, and Barrett.
Source: syllabus, lineup
Jackson filed a dissenting opinion, joined by Sotomayor as to Parts III and IV except for a footnote, and Sotomayor separately filed an opinion concurring in part and dissenting in part.
Source: syllabus, lineup