A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279
The Supreme Court unanimously ruled that disabled schoolchildren suing their schools for disability discrimination face the same legal standards as disabled people everywhere else — not a steeper, school-specific bar that had blocked many claims before they could go to trial.
The decision resolves a long-running disagreement among federal courts and means disabled students and their families can now pursue claims under the Americans with Disabilities Act and the Rehabilitation Act without having to clear an extra hurdle that Congress never wrote into those laws.
How it got here: A federal trial court granted summary judgment for the school district; the Eighth Circuit affirmed; the Supreme Court agreed to hear the case to resolve a circuit split on the standard of proof.
The Case in Depth
What happened
A teenage girl with a rare form of epilepsy experiences such frequent seizures in the morning that she cannot attend school before noon, but she is alert and able to learn from noon until about 6 p.m. A Minnesota school district repeatedly refused her parents' requests to include evening instruction in her educational plan, leaving her with about two fewer hours of school each day than her classmates. After winning a separate complaint under special education law, she and her parents sued the district for disability discrimination — but courts dismissed the case because she couldn't prove the school acted with "bad faith or gross misjudgment."
The question before the Court
Can public schools demand that disabled students meet a much tougher legal standard — "bad faith or gross misjudgment" — than disabled people in every other setting must meet when suing for disability discrimination?
The Court's answer
No — courts cannot require disabled students to prove "bad faith or gross misjudgment" to bring disability discrimination claims under the ADA and the Rehabilitation Act. The text of both laws extends its protections to all "qualified individuals" with disabilities and makes remedies available to "any person," with no language suggesting schoolchildren must clear a higher bar than anyone else. That asymmetric rule was irreconcilable with a federal statute Congress passed specifically to prevent special education law from limiting disabled children's independent rights under the ADA and the Rehabilitation Act.
The Court declined to address a broader argument the school district raised at oral argument — that "bad faith or gross misjudgment" should be required for all disability discrimination claims everywhere, inside and outside schools. That question was outside what the Court agreed to decide, had not been ruled on below, and was not fairly raised before the Court took the case.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Disabled students and their families who believe their school failed to provide legally required accommodations can now sue under the ADA and the Rehabilitation Act on equal footing with other disability discrimination plaintiffs. They no longer need to prove the school acted with "bad faith or gross misjudgment" — a threshold so high it effectively barred most school-based disability discrimination claims before they could reach a jury.
What changes now
The case returns to the lower courts for the student and her parents to pursue their ADA and Rehabilitation Act claims under the same standards that apply to disability discrimination cases outside the school context. On remand, courts will apply the general framework — which requires no showing of intent for injunctive relief, and typically requires at least "deliberate indifference" for compensatory damages. Whether the broader questions Justice Thomas flagged about the correct intent standard will reach the Court in a future case remains to be seen.
What this does not decide
The Court explicitly limited its holding to the school-specific "bad faith or gross misjudgment" double standard and did not decide what general intent standard governs ADA and Rehabilitation Act claims going forward. A broader challenge — whether proving intentional discrimination should be required for any relief under these statutes — was left entirely open for a future case.
Concurrences and dissents
Concurrence — Justice Thomas
Justice Thomas agrees the school-specific double standard is wrong, but writes to signal his willingness to reconsider whether the generally applicable standards are themselves correct. He questions whether the ADA and Rehabilitation Act — based on their text and constitutional foundations in the Spending Clause and limits on federal commandeering of states — should require proof of intent to discriminate before any violation can be found or any relief awarded, rather than allowing no-intent claims for injunctive relief as most courts currently permit.
Concurrence — Justice Sotomayor
Justice Sotomayor agrees with the majority and writes to directly rebut the school district's broader argument that the statutes require proof of 'animus' or 'improper purpose' for any claim. She argues the phrase 'by reason of' in both laws requires only a causal link between disability and exclusion — not bad intent — and that Congress understood when it enacted these laws that disability discrimination most often stems from thoughtlessness and indifference rather than ill will, which is precisely why an intent requirement would gut the statutes' core protections.
How the Court got there
The legal reasoning, step by step
- The Court started with the text of the two laws at issue. Both Title II of the ADA and Section 504 of the Rehabilitation Act extend their protections to 'qualified individuals' with disabilities without any carve-out by context, and both make their remedies available to 'any person' without qualification — no passage suggests schoolchildren's claims deserve less protection than anyone else's.
- The 'bad faith or gross misjudgment' rule originated in a 1982 Eighth Circuit decision (Monahan v. Nebraska) that tried to reconcile Rehabilitation Act claims with special education law by reasoning that courts should defer to educators unless their conduct was seriously deficient. This was nearly identical reasoning to what the Supreme Court itself used in Smith v. Robinson (1984), where the Court held that special education law was the only avenue for disabled students to challenge their education.
- Congress swiftly overturned Smith by adding what is now § 1415(l) to the Individuals with Disabilities Education Act (IDEA). That provision states in plain terms 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 — explicitly rejecting the idea that the IDEA caps what other antidiscrimination statutes can do.
- The Monahan rule violated this unambiguous command. By requiring disabled students to prove something more than other disability discrimination plaintiffs, it effectively used the IDEA's structure to limit children's independent ADA and Rehabilitation Act rights — precisely the outcome § 1415(l) was enacted to prevent.
- The school district, apparently conceding Monahan's school-specific rule was indefensible, pivoted at oral argument to argue that 'bad faith or gross misjudgment' should be the correct intent standard for all disability discrimination claims everywhere. The Court declined to address this new argument because it was outside the narrow question the Court had agreed to hear, had not been decided by the lower courts, and was not raised when the school district had the opportunity to flag it at the certiorari stage.
Doctrinal impact
Cases affected by this decision
Reaffirms Fry v. Napoleon Community Schools (580 U.S. 154)
The Court repeatedly relies on Fry's description of the IDEA and § 1415(l) as still-governing law.
Distinguishes Smith v. Robinson (468 U.S. 992)
Congress overturned Smith by enacting § 1415(l), so Smith's reasoning no longer supports imposing a heightened standard on school-based disability claims.