On June 12, 2025, the U.S. Supreme Court unanimously ruled in A.J.T. v. Osseo Area Schools that public school students bringing disability discrimination claims under the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act are not required to meet a heightened “bad faith or gross misjudgment” standard. The Court held that such claims are subject to the same legal standards applicable in other disability discrimination contexts, a decision that expands the ability of disabled students to seek relief in court.
Key Facts
The plaintiff, A.J.T., is a teenage girl with severe epilepsy. Due to her medical condition, A. J.T. was unable to attend school before noon due to frequent seizures but was alert and capable of learning from noon to 6 p.m. In her previous district, she received home instruction in the evening to accommodate her disability. After relocating to Minnesota in 2015, the Osseo Area School District refused her parents’ repeated requests to provide similar evening instruction as part of her Individualized Education Program (IEP). As a result, A.J.T. received fewer instructional hours each school day than her non-disabled peers.
When A.J.T. entered middle school, the District proposed further reducing the length of her school day. Her parents again requested that she receive evening home instruction and instructional hours comparable to the hours provided to her non-disabled peers. When this request was denied, A.J.T.’s parents filed a complaint under the Individuals with Disabilities Education Act (IDEA) alleging that the refusal to provide evening instruction denied A.J.T. with a free appropriate public education (FAPE). An administrative law judge (ALJ) found the school had violated the IDEA and ordered several hundred hours compensatory education. The ALJ further ordered that A.J.T.’s IEP be amended to include at-home instruction from 4:30-6:00 each school day. This decision was affirmed by both the district court and the Eighth Circuit which found that the district’s rationale for not providing the after-hours instruction was due to “administrative convenience” – namely, maintaining “the regular hours of the faculty” instead of the student’s needs.
The family subsequently filed suit under the ADA and Rehabilitation Act, seeking additional remedies, including compensatory damages. The district court granted summary judgment to the school district, using a standard that required a showing of “bad faith or gross misjudgment” to establish liability in education-related disability claims. The Eighth Circuit affirmed, despite acknowledging that the standard was unusually stringent.
Legal Analysis
The Supreme Court rejected the Eighth Circuit’s application of a heightened standard. Writing for a unanimous Court, Chief Justice Roberts stated that nothing in the text of the ADA or Section 504 justifies imposing a more demanding burden of proof on plaintiffs in the educational context. The Court emphasized that these statutes broadly prohibit discrimination “by reason of disability” and apply equally across contexts. The Court noted that in other cases under the ADA and Section 504, plaintiffs can establish a violation and obtain injunctive relief without proving intent to discriminate. In claims for compensatory damages, the requirement to show “intentional discrimination” is satisfied by a showing of “deliberate indifference.” There is no requirement that the plaintiff prove personal ill will or animosity toward disabled persons. In order to show deliberate indifference, the plaintiff must prove that the defendant disregarded a “strong likelihood” that the challenged action would “result in a violation of federally protected rights.” The Court held that these standards also apply to cases in the education context.
The Court also highlighted that Congress explicitly rejected the idea that IDEA remedies are exclusive. In 1986, Congress added a provision to the IDEA—codified at 20 U.S.C. §1415(l)—making clear that nothing in the IDEA limits the rights or remedies available under other federal laws like the ADA or Section 504. This means that separate claims can be brought against school districts under the IDEA and the ADA/Section 504 by students with disabilities or their parents. The Court held that in imposing a “higher bar for claims based on educational services” as compared to other disability-related discrimination contexts would “implicitly limit the ability of children with disabilities to vindicate their independent ADA and Rehabilitation Act rights.”
The decision vacates the Eighth Circuit’s ruling and remands for further proceedings under the correct legal standard, which may include a showing of deliberate indifference to obtain compensatory damages, but does not require proof of bad faith.
Implications for Schools and Educational Institutions
- Unified Standard: The ruling aligns education-related disability discrimination claims with other ADA and Rehabilitation Act contexts, removing the special, elevated evidentiary requirement. This ruling applies to all public school districts throughout the country.
- Ohio Impact: The Sixth Circuit, which includes Ohio, utilized the “bad faith or gross misjudgment” standard that was used by the Eighth Circuit and overturned by the U.S. Supreme Court in this case. Consequently, this is a shift for all Ohio public school districts.
- Increased Exposure: Public schools may now face greater exposure to liability under federal anti-discrimination statutes if accommodations are denied—even absent proof of animus or gross misjudgment.
- Potential for More Litigation: With the lowered barrier to bringing claims, public schools should prepare for the possibility of increased litigation under the ADA and Section 504.
- Policy Adjustments: School districts should review nondiscrimination policies to ensure compliance with federal disability laws under the clarified standard.
If you have any questions regarding this case or the impact on your school district, please do not hesitate to reach out to Christina Henagen Peer or any of our attorneys in the Weston Hurd Education Law Group.
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About the Author
Christina Henagen Peer is a Weston Hurd Partner who focuses her practice on education law. She provides counsel to boards of education on numerous matters including student discipline, employee grievances, employee evaluation and discipline issues, the First Amendment, public records requests including Sunshine Laws, records retention policies, social media issues, residency and custody disputes, and the drafting and implementation of board policies. Her practice includes a significant focus on state and federal laws relating to the education of students with disabilities. Christina can be contacted via email at cpeer@westonhurd.com or by phone at 216-687-3372.
