Former employee sued over benefits plan change: Why court dismissed ADA lawsuit

Due to a city’s decision to change its benefits plan, a former firefighter battling Parkinson’s lost a valuable fringe benefit: a subsidy that covered her health insurance premiums. Then she filed a lawsuit, alleging ADA and other claims.
Debilitating disease ends career
In 2016, Karyn Stanley was working as a firefighter for the city of Sanford, Florida, when she was diagnosed with Parkinson’s disease. At the time, she was a veteran at the station with about 15 years under her belt.
Two years later, the disease and accompanying physical disabilities left her unable to do the job. At the age of 47, Stanley took disability retirement on Nov. 1, 2018.
Policy change affects retiree’s benefits plan
When Stanley originally joined the fire department in 1999, qualified disability retirees received free health insurance until they turned 65. But that policy was changed in 2003.
The new benefits plan limited the health insurance subsidy to 24 months after retirement.
Just before that 24-month period ended, Stanley filed a lawsuit against the city, alleging, among other things, that eliminating the health insurance subsidy for retirees with disabilities amounted to discrimination in violation of Title I of the ADA.
The district court granted the city’s motion to dismiss Stanley’s ADA claim, and Stanley appealed to the Eleventh Circuit.
What the ADA says
First things first: One crucial element of a valid ADA claim is establishing that a plaintiff is a qualified individual with a disability.
Under the ADA, a qualified individual with a disability is someone “who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires” is protected from disability discrimination, the Eleventh Circuit explained. (Emphasis in original.)
The terms “can,” “holds” and “desires” are all present tense, the court pointed out. As such, it reasoned that a “plaintiff must desire or already have a job with the defendant” at the time of the alleged discriminatory act “to be a victim of unlawful disability discrimination.”
Here, Stanley was disabled in December 2020 when the new policy stopped covering her health insurance premiums. But by that time, Stanley was a retiree, not an employee, the court noted.
“She did not hold, desire to hold, nor was she qualified to hold ‘an employment position’ with the City, as required by Title I’s anti-discrimination provision,” the court held.
Stanley wasn’t a qualified individual with a disability so she couldn’t bring an ADA claim. The Eleventh Circuit affirmed the lower court’s ruling to dismiss the claim.
Stanley v. City of Sanford, Florida, No. 22-10002, 2023 U.S. App. LEXIS 27000 (11th Cir. 10/11/23).
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