Facts of the Case

Provided by Oyez

A.J.T., a student with epilepsy, experiences seizures so severe in the morning that she cannot attend school until noon. Her parents repeatedly requested evening instruction from Osseo Area Schools to give her a school day length more comparable to her peers. Despite the District providing some accommodations, including one-on-one instruction, a slightly extended school day, and summer home instruction sessions, they denied the requests for evening instruction. The District’s Director of Student Services, responsible for Section 504 compliance, was unaware of the parents’ complaints and did not know that District policies allowed at-home schooling as an accommodation. A.J.T., through her parents, sued the District for disability discrimination under Section 504 of the Rehabilitation Act and the Americans with Disabilities Act. The district court granted summary judgment in favor of the District, and the U.S. Court of Appeals for the Eighth Circuit affirmed.

Questions

  1. Do the Americans with Disabilities Act of 1990 and Rehabilitation Act of 1973 require children with disabilities to satisfy a “bad faith or gross misjudgment” standard when seeking relief for discrimination relating to their education?

Conclusions

  1. 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” but instead are subject to the same standards that apply in other disability discrimination contexts. Chief Justice John Roberts authored the unanimous opinion of the Court.

    When the Individuals with Disabilities Education Act (IDEA) was amended in 1986, Congress explicitly declared that nothing in the IDEA “shall be construed to restrict or limit the rights, procedures, and remedies available under” the Americans with Disabilities Act (ADA), the Rehabilitation Act, or other federal laws protecting disabled children's rights. This provision directly repudiates judicial attempts to create special barriers for educational discrimination claims. The Eighth Circuit’s rule requiring schoolchildren to prove “bad faith or gross misjudgment”—rather than the standard deliberate indifference required in other disability contexts—artificially limits disabled students’ ability to vindicate their rights under the ADA and Rehabilitation Act. Neither statute’s text suggests that educational services claims deserve different treatment than other disability discrimination claims. Both laws use expansive language applying protections to “any person” alleging discrimination, without distinction based on the type of claim.

    The heightened standard originated in 1982 when the Eighth Circuit attempted to “harmonize” the IDEA with the Rehabilitation Act, reasoning that courts should defer to educators unless they departed grossly from professional standards. This Court made a similar harmonization attempt in 1984, holding the IDEA was the exclusive remedy for educational claims, but Congress swiftly overturned that decision. The Eighth Circuit’s continued application of its heightened standard conflicts with Congress’s clear directive that the IDEA does not limit other federal antidiscrimination laws. By imposing a higher burden of proof for educational claims compared to other disability discrimination contexts, courts effectively read the IDEA as restricting the independent rights and remedies that Title II and Section 504 provide to disabled children.

    Justice Clarence Thomas authored a concurring opinion, joined by Justice Brett Kavanaugh, suggesting the Court should consider in a future case whether intent to discriminate must be proven for all ADA and Rehabilitation Act claims, not just educational ones.

    Justice Sonia Sotomayor authored a concurring opinion, joined by Justice Ketanji Brown Jackson, emphasizing that the ADA and Rehabilitation Act require no showing of improper purpose or animus because discrimination against people with disabilities often results from thoughtlessness rather than malice.