U.S. Supreme Court Update
The U.S. Supreme Court has ruled on two cases this year that impact labor and employment law. We introduced both cases in October, 2024.
First, many of the civil rights laws that apply to the employment relationship permit an award of attorney’s fees to the prevailing party. The case of Lackey v. Stinnie presented the question of whether a party is a “prevailing party” when it obtains a preliminary injunction. In February, the Supreme Court answered “no,” and explained: “Preliminary injunctions do not make a party ‘prevailing’ because they do not conclusively decide the case on the merits. Such injunctions only determine if a plaintiff is likely to succeed, . . .” Instead, a party “prevails” “when a court grants enduring judicial relief that materially alters the legal relationship between the parties.”
Second, in Stanley v. City of Sanford, the Court ruled that the Americans with Disabilities Act did not apply to a retiree who could no longer work because of a disability. Here, the plaintiff took early retirement due to Parkinson’s disease. She alleged that a change to city policy which resulted in her receiving only two years of free health insurance after retirement discriminated against disabled workers. The issue for the Court was whether the ADA allows a former employee to sue over post-employment benefits. In June, the Court ruled that to prevail under Title I of the ADA, a plaintiff must prove that she held or desired a job and could perform its essential functions with or without reasonable accommodation at the time of the employer’s alleged disability-based discrimination. While retirement benefits are compensation protected under the ADA, the Act protects only a “qualified individual” who can perform the essential functions of the job held or desired with or without reasonable accommodation. Since this plaintiff was no longer able to perform the essential functions of her job, she was not a qualified individual protected by the ADA.
This ruling does not mean, however, that retired individuals can never recover under the ADA. The Court cautioned that the ADA may protect other retired individuals depending upon the facts of their case because unlawful discrimination can take place at any one of three points in time: when an employer adopts a discriminatory practice, when an individual is affected by application of the discriminatory practice, or when an individual becomes subject to the practice.
If you have questions about these issues or cases, please contact a KZA attorney.
KZA Employer Report articles are for general information only; they are not intended and should not be construed to be legal advice. Reading or replying to such articles does not establish an attorney-client relationship. In addition, because the subject matters and applicable laws discussed in Employer Report articles are often in a state of change and not always applicable to every type of business entity or organization, readers should consult with counsel before making decisions based on the same.