A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279
Headline: Court rejects heightened intent rule for disability discrimination in schools, allowing students to challenge denied accommodations under the ADA and Rehabilitation Act like other contexts.
Holding: The Court held that students bringing ADA and Rehabilitation Act claims about their education need not show “bad faith or gross misjudgment” and instead face the same standards as other disability discrimination claims.
- Makes it easier for students to seek court-ordered accommodations without proving bad faith.
- Keeps compensatory damages available but usually requires deliberate indifference proof.
- Requires lower courts to re-examine denied accommodations under ordinary ADA/Section 504 standards.
Summary
Background
A teenage girl with a rare epilepsy and her parents sued a Minnesota public school district after the district refused to add evening instruction to her IEP. Her seizures prevent school before noon, leaving about 4.25 hours of instruction daily instead of the usual 6.5. An administrative law judge found the district violated the IDEA and ordered compensatory education and evening instruction, and federal courts affirmed. The family then sued under the ADA and Section 504 seeking an injunction, reimbursement, and compensatory damages. The district court and the Eighth Circuit dismissed the ADA/504 claims, applying a longstanding Eighth Circuit rule requiring proof of “bad faith or gross misjudgment” for education-related claims.
Reasoning
The Court asked whether that heightened intent requirement applies to school-based ADA and Section 504 claims and held it does not. It explained that the statutory text of Title II and Section 504 contains no special rule for schools and that 20 U.S.C. §1415(l) preserves ADA and Section 504 rights even when an IDEA remedy overlaps. The Court said courts elsewhere require no intent for injunctive relief, while compensatory damages usually require intentional discrimination shown by “deliberate indifference.” The Court vacated the Eighth Circuit’s judgment and remanded.
Real world impact
Students with disabilities and their families can pursue ADA and Rehabilitation Act claims about schooling without proving “bad faith or gross misjudgment.” That makes it easier to seek court orders for accommodations and services, while damages generally still require proof of deliberate indifference. The ruling is not a final merits decision and the case goes back to lower courts for further proceedings.
Dissents or concurrances
Justice Thomas, joined by Justice Kavanaugh, wrote separately, saying future cases might decide broader statutory and constitutional questions. Justice Sotomayor, joined by Justice Jackson, stressed that the ADA and Rehabilitation Act reach failures to accommodate caused by indifference, not only by improper motive.
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