June 12, 2025

Overview
The U.S. Supreme Court unanimously ruled in A.J.T. v. Osseo Area Schools that schoolchildren with disabilities suing under the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act for education-related discrimination do not need to prove “bad faith or gross misjudgment” by school officials.

This decision overturns a stricter standard applied by some courts, aligning educational discrimination claims with the less demanding “deliberate indifference” standard used in other disability discrimination contexts. The case arose from a Minnesota teenager, A.J.T., whose school district refused to provide evening instruction to accommodate her epilepsy-related needs. The ruling strengthens protections for disabled students, potentially increasing schools’ accountability for providing equal educational access.

Facts

• A.J.T., a teenager with severe epilepsy, cannot attend school before noon due to frequent morning seizures but can learn from noon to 6 p.m.
• From 2015 to 2018, Osseo Area Schools in Minnesota provided A.J.T. only 4.25 hours of daily instruction, compared to 6.5 hours for nondisabled students.
• A.J.T.’s parents requested evening instruction to match her peers’ school day, but the district denied these requests.
• In 2018, an Administrative Law Judge ruled the district violated the Individuals with Disabilities Education Act (IDEA) by denying A.J.T. a free appropriate public education, ordering compensatory education and evening instruction.
• A.J.T.’s subsequent ADA and Rehabilitation Act claims for damages and injunctive relief were dismissed by the Eighth Circuit, citing a 1982 precedent (Monahan v. Nebraska) requiring proof of “bad faith or gross misjudgment.”
• On June 12, 2025, the Supreme Court vacated the Eighth Circuit’s decision, ruling that the heightened standard does not apply to educational discrimination claims.

Perspectives

• A.J.T.’s Legal Team (Latham & Watkins): Roman Martinez, representing A.J.T., argued that the “bad faith or gross misjudgment” standard unfairly burdens disabled students, who are among the most vulnerable to discrimination. He emphasized that the ADA and Rehabilitation Act provide critical remedies for educational discrimination, and the ruling restores equal treatment under these laws.
• Osseo Area Schools: The district maintained that it offered alternative accommodations to meet A.J.T.’s needs while managing limited resources. They argued that the ADA and Rehabilitation Act require proof of intentional discrimination, and their actions did not reflect discriminatory intent.
• Council of Parent Attorneys and Advocates: This advocacy group supported A.J.T., asserting that the heightened standard creates a “nearly insurmountable barrier” for disabled students seeking redress. They welcomed the ruling as a step toward equitable access to education.
• National School Attorneys Association: Representing school districts, this group cautioned that lowering the legal threshold could strain school resources and foster adversarial relationships with parents, potentially diverting funds from education to litigation.

Considerations

• The ruling clarifies that disabled students have the same legal protections under the ADA and Rehabilitation Act as other plaintiffs, promoting consistency in disability rights enforcement.
• Schools may face increased litigation as the “deliberate indifference” standard lowers the bar for proving discrimination, potentially impacting district budgets.
• Enhanced accountability could drive schools to proactively improve accommodations, reducing disparities in educational access for disabled students.
• The decision reinforces the IDEA’s provision (20 U.S.C. §1415(l)) that it does not limit remedies under other federal laws, preserving multiple avenues for redress.
• Long-term, the ruling may influence how schools allocate resources to balance compliance with disability laws and general educational needs.
• The case now creates a uniform national standard for educational discrimination claims.

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