A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279, Docket No. 24-249
Listen to the episode on Spotify
At the center of a subtle change in disability law, the Supreme Court has said that students claiming their schools discriminated against them don’t have to prove that officials acted in “bad faith or gross misjudgment.” Instead, those students use the same straightforward rules that apply to other cases of disability discrimination.
This ruling overturns a higher bar set by the Eighth Circuit, which had made it tougher for students to bring their claims forward. Now the Supreme Court sent the case back to that court to be handled under the usual standards.
With this decision, families will face a clearer path when they say their children were denied equal access in the classroom. Stay tuned—we’ll break down what this means for schools and for kids across the country.
Summary of the Case
A. J. T. is a teenage student with a severe form of epilepsy whose seizures preclude her from attending school before noon but leave her able to learn from noon to 6 p.m. After moving to Osseo Area Schools (Dist. No. 279), her parents twice sought to include evening instruction in her IEP; the district denied those requests, cutting her instructional day to 4.25 hours versus 6.5 for nondisabled peers. They prevailed on an IDEA administrative complaint and in federal court, securing compensatory education and after-hours instruction. They then sued under Title II of the ADA and § 504 of the Rehabilitation Act. The Eighth Circuit affirmed summary judgment for the district on the ground that educational discrimination claims require a heightened showing of "bad faith or gross misjudgment" (Monahan v. Nebraska), which A. J. T. had not made. The Supreme Court granted certiorari to resolve the circuit split over whether ADA/§ 504 claims involving public-school services must satisfy that elevated standard.
Opinion of the Court
Chief Justice Roberts, writing for a unanimous Court, held that Title II and § 504 claimants relating to educational services are subject to the same requirements applied elsewhere under those statutes—no showing of intent to discriminate is required to obtain injunctive relief, and intentional discrimination (often shown by "deliberate indifference") is required only for compensatory damages. The Court observed that both statutes prohibit discrimination "by reason of" disability and confer remedies on "any person." It rejected the Eighth Circuit's Monahan-derived "bad faith or gross misjudgment" rule as incompatible with IDEA's non-exclusivity provision, and vacated and remanded the judgment.
Separate Opinions
Justice Thomas (joined by Justice Kavanaugh) concurred in full but stated that, in a future case properly presented, he would revisit whether ADA/§ 504 should uniformly require intent to discriminate—contending that "discrimination" necessarily implies intent and that Title II's prescriptions on States implicate Spending- and Fourteenth-Amendment limits.
Justice Sotomayor (joined by Justice Jackson) emphasized that the statutes' text and legislative history refute any improper-purpose gloss, underscoring that discrimination "most often" stems from "benign neglect" and that passive-voice drafting and affirmative-accommodation duties confirm no animus requirement.
How Disability Discrimination Standards Apply in Education Settings
The relationship between different disability laws is crucial to understanding this case. The Americans with Disabilities Act (ADA) and the Rehabilitation Act broadly prohibit discrimination based on disability and allow for both injunctive relief and monetary damages. Meanwhile, the Individuals with Disabilities Education Act (IDEA) specifically ensures appropriate education through individualized programs.
After a previous Supreme Court case limited disability rights, Congress clarified that IDEA procedures don't restrict rights available under the ADA or Rehabilitation Act. The Eighth Circuit's requirement for showing "bad faith or gross misjudgment" in education cases improperly narrowed the protections that should be available under disability discrimination laws.
The Court's ruling confirms that the standards for proving discrimination should be consistent across different contexts - whether in schools, workplaces, or public services. For injunctive relief (like ordering a school to provide evening instruction), no proof of discriminatory intent is needed. Only when seeking monetary damages must a plaintiff show intentional discrimination, typically through evidence of "deliberate indifference" to their rights.