Student Disability Claims are Not Held to a Heightened Standard

In A.J.T. v. Osseo Area Schools, Independent School District No. 279, 605 U.S. ____ (2025), the U.S. Supreme Court held that schoolchildren bringing claims related to their education under either Title II of the Americans with Disabilities Act or Section 504 of the Rehabilitation Act are not required to make a heightened showing of “bad faith or gross misjudgment.” Rather, they are subject to the same standards that apply in other disability discrimination contexts.

Facts of the Case

Several federal laws afford protections for children with disabilities in public schools. Section 504 of the Rehabilitation Act of 1973 provides that no qualified individual with a disability shall be excluded from participation in, denied the benefits of, or subjected to discrimination under any federally funded program solely by reason of her or his disability. Similarly, Title II of the Americans with Disabilities Act (ADA) prohibits qualified individuals with disabilities from being excluded from or denied the benefits of a public entity’s services, programs, or activities by reason of disability.

A third statutory scheme, the Individuals with Disabilities Education Act (IDEA), offers federal funds to States in exchange for the commitment to furnish the core guarantee of a “free appropriate public education” to children in public schools with certain physical or intellectual disabilities. The centerpiece of the IDEA is the provision of an “individualized educational program,” (IEP) which details a plan to meet all of the educational needs of a child with a qualifying disability.

Petitioner A.J.T. is a teenage girl with a rare form of epilepsy that severely limits her physical and cognitive functioning. She suffers from seizures that are so frequent in the mornings that she can’t attend school before noon, though she is alert and able to learn from noon until 6 p.m.

For the first few years of her schooling, school officials accommodated A.J.T.’s condition by permitting her to avoid morning activities and instead receive evening instruction. However, when A.J.T.’s family moved to Minnesota in 2015, her new school district—Osseo Area Public Schools, Independent District No. 279—denied her parents’ repeated requests to include evening instruction in A.J.T.’s IEP.

Between 2015 and 2018, A.J.T. received only 4.25 hours of instruction daily compared to the typical 6.5-hour school day for nondisabled students in the district. After even further cuts to A. J. T.’s school day were proposed, her parents filed an IDEA complaint with the Minnesota Department of Education, alleging that the school’s refusal to provide afterhours instruction denied A.J.T. a free appropriate public education.

An Administrative Law Judge determined that the school district had violated the IDEA and ordered the school to provide compensatory education and evening instruction. The federal court affirmed. A.J.T. and her parents subsequently filed suit under the ADA and the Rehabilitation Act, requesting a permanent injunction, reimbursement for certain costs, and compensatory damages.

The District Court granted summary judgment for the school, and the Eighth Circuit Court of Appeals affirmed. It held that a school district’s failure to provide a reasonable accommodation was not enough to state a prima facie case of discrimination under Monahan v. Nebraska, 687 F. 2d 1164 (1982), which requires a plaintiff to prove conduct by school officials rising to the level of bad faith or gross misjudgment. According to the appeals court, that standard applies uniquely in the educational services context and requires a more demanding showing compared to other sorts of disability discrimination claims.

Supreme Court’s Decision

The Supreme Court disagreed, holding that the lower courts erred in requiring a heightened showing. “We hold today that ADA and Rehabilitation Act claims based on educational services should be subject to the same standards that apply in other disability discrimination contexts,” Chief Justice John Roberts wrote on behalf of the unanimous Court. He further explained:

Nothing in the text of Title II of the ADA or Section 504 of the Rehabilitation Act suggests that such claims should be subject to a distinct, more demanding analysis. The substantive provisions of both Title II and Section 504, by their plain terms, apply to “qualified individual[s]” with disabilities. There is no textual indication that the protections of either disability discrimination statute apply with lesser force to certain qualified individuals bringing certain kinds of claims.

Nor do the applicable remedial provisions suggest any such distinction. Both Title II and Section 504 make the “remedies, procedures, and rights” provided therein available to “any person.” 29 U. S. C. §794a(a)(2) (“any person aggrieved”); 42 U. S. C. §12133 (“any person alleging discrimination”). That language is expansive and unqualified, confirming applicability to every such person, “without distinction or limitation.”

The Court went on to address how courts like the Eighth Circuit have come to apply a heightened intent standard to ADA and Rehabilitation Act claims in the educational services context, noting that the standard traces back to the “bad faith or gross misjudgment” rule articulated by the Eighth Circuit in its decision in Monahan. According to the Court, the standard conflicts with amendments to the IDEA, codified at 20 U.S.C. §1415(l), which provide that nothing in the IDEA “shall be construed to restrict or limit the rights, procedures, and remedies available under” the ADA, Rehabilitation Act, or other federal laws protecting disabled children’s rights. “The plain text of §1415(l) accordingly makes clear that nothing in the IDEA ‘restrict[s] or limit[s] the rights [or] remedies’ that other federal laws, including antidiscrimination statutes, confer on children with disabilities,” Chief Justice Roberts wrote.

Finally, the Court addressed the school districts that bad faith or gross misjudgment is the

correct standard of intent for all ADA and Rehabilitation Act claims, whether in or out of schools. Because the argument was not resolved below, was not raised in the brief in opposition to certiorari, and is outside the question presented, the justices declined to reach the issue.