Supreme Court Rules Students with Disabilities Must Meet Same Standard as Other Discrimination Claims
On June 12, 2025, the U.S. Supreme Court (Court) issued its opinion in A.J.T., et al. v. Osseo Area Schools, Indep. Sch. Dist. No. 279, et al. The Court vacated the 8th circuit court’s decision and remanded the case while setting forth that the same standard must be applied by courts in cases involving alleged failures to accommodate students with disabilities under the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act (Rehabilitation Act) as in other disability discrimination contexts. Chief Justice Roberts delivered the unanimous opinion for the Court.
Petitioner A. J. T. is a young female student who suffers from seizures throughout the day that create safety concerns and interfere with her capacity to learn. Her seizures are so frequent in the morning that she “can’t attend school before noon,” however, she is “alert and able to learn” from noon until about 6 p.m. Until middle school, she had been provided reasonable accommodation although at a reduced number of hours for her school day compared with other students. Prior to the start of middle school, the school district proposed further cutting back the length of her school day. A. J. T.’s parents had requested that she receive evening instruction and schooling hours comparable to her nondisabled peers, however, school administrators again denied those requests and also rejected proposals to maintain at least the same length instructional day that A. J. T. had been receiving in elementary school. A. J. T.’s parents filed an IDEA complaint with the Minnesota Department of Education, alleging that the school’s refusal to provide after-hours instruction denied A. J. T. a free appropriate public education. The parents were successful on the IDEA complaint.
A. J. T. and her parents also sued the school district and the Osseo School Board (collectively, the District) in federal court, alleging violations of Title II of the ADA and Section 504 of the Rehabilitation Act. The courts below held that A. J. T.’s claims under the ADA and the Rehabilitation Act could not go forward because she had not shown that school officials acted with “bad faith or gross misjudgment.” That heightened standard, the lower courts explained, applies uniquely in the educational services context and requires a more demanding showing compared to other sorts of disability discrimination claims.
The Supreme Court found there was no evidence in the statutory language or legislative history that supported imposing such a high burden on students when other groups with disabilities would not be required to show bad faith or gross misjudgment to bring a discrimination claim. As a result, the Supreme Court ruled in favor of the student and determined that students with disabilities filing claims under the ADA and Rehabilitation Act are held to the same standard as other individuals alleging disability discrimination in different contexts.
A copy of the case can be found here.