Karyn Stanley worked as a firefighter for the City of Sanford in Florida from 1999 until 2018. In 2016, she was diagnosed with Parkinson’s disease, and worked for about two more years before her disease prevented her from performing her job. She began receiving disability retirement benefits.
When Stanley first joined the fire department, employees retiring for qualifying disabilities such as Parkinson’s disease were entitled to free health insurance until the age of 65. However, unbeknownst to Stanley, the policy changed in 2003. Under the new rules, disability retirees were entitled to free health insurance for two years after retirement. Stanley retired at age 47 and would have been responsible for her own health insurance far earlier than she anticipated.
Stanley sued the City for discrimination on the basis of her disability under the Americans with Disabilities Act and several other statutes. Her claim was dismissed because under the prevailing case law, the cessation of Stanley’s health benefits would occur while she was no longer employed by the City. In order for Stanley to have a claim, she would need to be an active employee when the alleged discrimination occurred.
Stanley appealed to the 11th Circuit Court of Appeals, which upheld the lower court’s opinion. The Court rejected several arguments, concluding that the district court applied the correct law to this case. The critical question to resolve was “whether Stanley was a disabled employee or job applicant capable of performing the job at the time of the alleged discrimination.” The Court determined that whenever Stanley alleged the discrimination took place, her argument fails, whether it was (1) in 2003 when the retiree disability policy was changed; (2) in 2020, when her health insurance was terminated; or (3) at some point between 2016 when she was diagnosed and 2018 when she separated from employment. The Court easily rejected options (1) and (2) because Stanley was not disabled in 2003, and Stanley was incapable of performing her job duties in 2020. The Court conceded that it might be possible for Stanley to state a claim if she alleged the discrimination occurred while she was still an employee – i.e., option (3). The Court declined to consider this argument because Stanley did not raise it prior to her appeal. Therefore, Stanley did not state a claim for discrimination on the basis of disability because she was either not disabled or not an employee at the time of the alleged discrimination.
Stanley v. City of Sanford, Florida, 2023 WL 6614448 (11th Cir. 2023).