A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279, 605 U.S. ___ (2025)
A.J.T., a teenage girl with a rare form of epilepsy, moved to Minnesota in 2015. Her new school district, Osseo Area Public Schools, denied her parents' requests to include evening instruction in her Individualized Educational Program (IEP), despite her inability to attend school before noon due to frequent morning seizures. Consequently, A.J.T. received only 4.25 hours of instruction daily, compared to the typical 6.5-hour school day for nondisabled students. After further cuts to her school day were proposed, her parents filed an IDEA complaint, alleging that the refusal to provide afterhours instruction denied A.J.T. a free appropriate public education.
An Administrative Law Judge ruled in favor of A.J.T., finding that the school district violated the IDEA and ordered compensatory education and evening instruction. The Federal District Court and the Eighth Circuit Court of Appeals affirmed this decision. However, when A.J.T. and her parents sued under the ADA and the Rehabilitation Act, the District Court granted summary judgment for the school, and the Eighth Circuit affirmed, stating that a plaintiff must prove bad faith or gross misjudgment by school officials to establish a prima facie case of discrimination.
The Supreme Court of the United States reviewed the case and held that schoolchildren bringing ADA and Rehabilitation Act claims related to their education are not required to make a heightened showing of bad faith or gross misjudgment. Instead, they are subject to the same standards that apply in other disability discrimination contexts. The Court vacated the Eighth Circuit's judgment and remanded the case for further proceedings consistent with this opinion.
ADA and Rehabilitation Act claims based on educational services are subject to the same standards that apply in other disability discrimination contexts.
SUPREME COURT OF THE UNITED STATES
Syllabus
A. J. T., by and through her parents, A. T., et al. v. OSSEO AREA SCHOOLS, INDEPENDENT SCHOOL DISTRICT NO. 279, et al.
certiorari to the united states court of appeals for the eighth circuit
No. 24–249. Argued April 28, 2025—Decided June 12, 2025
Multiple federal laws afford protections for children with disabilities in public schools. Three statutory schemes are particularly relevant to this case. 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. While the antidiscrimination guarantees of Section 504 and Title II apply in a variety of contexts, 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 “spells out” a plan to meet all of the educational needs of a child with a qualifying disability. Fry v. Napoleon Community Schools, 580 U.S. 154, 158.
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 cannot 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. But 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. Federal courts subsequently affirmed A. J. T.’s IDEA victory.
A. J. T. and her parents then sued 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 affirmed. In so holding, the Eighth Circuit stated 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, which requires a plaintiff to prove conduct by school officials rising to the level of bad faith or gross misjudgment.
Held: Schoolchildren bringing ADA and Rehabilitation Act claims related to their education 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. Pp. 7–14.
(a) Outside the educational services context, courts of appeals permit plaintiffs to establish violations and obtain injunctive relief under the ADA and Rehabilitation Act without proving intent to discriminate. To obtain compensatory damages, courts generally require a showing of intentional discrimination, which most circuits find satisfied by “deliberate indifference”—a standard requiring only a showing that the defendant disregarded a strong likelihood that the challenged action would violate federally protected rights. Nothing in the text of the applicable substantive protections or remedial provisions of Title II of the ADA or Section 504 of the Rehabilitation Act suggests that claims based on educational services should be subject to a distinct, more demanding analysis. Pp. 7–8.
(b) Some courts, however, have come to apply a heightened intent standard to ADA and Rehabilitation Act claims in the educational services context. This standard traces back to the “bad faith or gross misjudgment” rule articulated by the Eighth Circuit in its 1982 decision in Monahan, in which the Eighth Circuit reasoned that to prove discrimination under the Rehabilitation Act in the educational context, a plaintiff must show “something more than a mere failure to provide” a free appropriate public education. 687 F. 2d, at 1170. The court explained a heightened showing of bad faith or gross misjudgment was necessary to “harmonize” the Rehabilitation Act and the IDEA and to reflect the proper balance between disabled children’s rights, state officials’ responsibilities, and courts’ competence in technical fields. Id., at 1171.
In Smith v. Robinson, 468 U.S. 992, this Court similarly tried to “harmonize” the IDEA’s specific guarantee of a free appropriate public education with the protections of other antidiscrimination laws, ultimately concluding that the IDEA’s comprehensive statutory scheme was the exclusive avenue by which a disabled child or his parents could challenge the adequacy of his education. Within two years, however, Congress enacted a new provision of the IDEA overturning Smith. That provision, now codified at 20 U. S. C. §1415(l), provides 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. This provision makes clear that the IDEA does not restrict or limit rights or remedies that other federal antidiscrimination statutes independently confer on children with disabilities. The bad faith or gross misjudgment rule derived from Monahan is irreconcilable with the unambiguous directive of §1415(l). In imposing a higher bar for discrimination claims based on educational services as compared to other sorts of disability discrimination claims, the Eighth Circuit effectively read the IDEA to implicitly limit the ability of disabled schoolchildren to vindicate their independent ADA and Rehabilitation Act rights, thereby making it more difficult to secure the statutory remedies provided by Congress. Pp. 8–12.
(c) The school district no longer defends Monahan’s asymmetric rule, and contends instead 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. This argument was not resolved below, was not raised in the brief in opposition to certiorari, and is outside the question presented. The Court declines the invitation to inject into this case significant issues that have not been fully presented. Pp. 12–14.
96 F. 4th 1058, vacated and remanded.
Roberts, C. J., delivered the opinion for a unanimous Court. Thomas, J., filed a concurring opinion, in which Kavanaugh, J., joined. Sotomayor, J., filed a concurring opinion, in which Jackson, J., joined.
Judgment VACATED and case REMANDED. Roberts, C. J., delivered the opinion for a unanimous Court. Thomas, J., filed a concurring opinion, in which Kavanaugh, J., joined. Sotomayor, J., filed a concurring opinion, in which Jackson, J., joined. |
Argued. For petitioner: Roman Martinez, Washington, D. C.; and Nicole F. Reaves, Assistant to the Solicitor General, Department of Justice, Washington, D. C. (for United States, as amicus curiae.) For respondents: Lisa S. Blatt, Washington, D. C. |
Reply of A.J.T. submitted. |
Reply of petitioner A.J.T. filed. (Distributed) |
Reply of petitioner A.J.T. filed. (Distributed) |
Motion of the Solicitor General for leave to participate in oral argument as amicus curiae and for divided argument GRANTED. |
Brief amici curiae of Tennessee, et al. filed. (Distributed) |
Amicus brief of State of Tennessee and 6 Other States submitted. |
Amicus brief of AASA – THE SCHOOL SUPERINTENDENTS ASSOCIATION AND 8 OTHER EDUCATION ASSOCIATIONS submitted. |
Brief amici curiae of The School Superintendents Association (AASA), et al. filed. (Distributed) |
Brief amici curiae of The School Superintendents Association (AASA), et al. filed. (Distributed) |
Brief amici curiae of Tennessee, et al. filed. (Distributed) |
Sealed material from the United States District Court for the District of Minnesota electronically received and available with the Clerk. |
Brief of respondents Osseo Area Schools, et al. filed. (Distributed) |
Brief of respondents Osseo Area Schools, et al. filed. (Distributed) |
Brief of Osseo Area Schools, et al. submitted. |
CIRCULATED |
Motion of United States for leave to participate in oral argument and for divided argument submitted. |
Motion of the Deputy Solicitor General for leave to participate in oral argument as amicus curiae and for divided argument filed. |
Motion of the Deputy Solicitor General for leave to participate in oral argument as amicus curiae and for divided argument filed. |
Record received from the United States Court of Appeals for the Eighth Circuit and available with the Clerk (one box). |
Brief amici curiae of Representative Tony Coelho, et al. filed. |
Brief amicus curiae of United States filed. |
Brief amici curiae of Representative Tony Coelho, et al. filed. |
Amicus brief of Representative Tony Coelho and Coelho Center for Disability Law, Policy and Innovation submitted. |
Amicus brief of United States submitted. |
Brief amicus curiae of United States filed. |
Brief amici curiae of Council of Parent Attorneys and Advocates, et al. filed. |
Brief amici curiae of Council of Parent Attorneys and Advocates, et al. filed. |
Amicus brief of Council of Parent Attorneys and Advocates and Eleven Other Disability-Rights Organizations submitted. |
Joint appendix (2 volumes) filed. (Statement of costs filed) |
Joint appendix filed. (Statement of costs filed) |
Brief of petitioner A.J.T. filed. |
Joint Appendix submitted. |
Joint appendix (2 volumes) filed. (Statement of costs filed) |
Brief of A.J.T. submitted. |
Record requested from the United States Court of Appeals for the Eighth Circuit. |
Brief of petitioner A.J.T. filed. |
SET FOR ARGUMENT on Monday, April 28, 2025. |
Petition GRANTED. |
Notice of Supplemental Authority of A.J.T. submitted. |
Notice of Supplemental Authority of A.J.T. submitted. |
DISTRIBUTED for Conference of 1/17/2025. |
DISTRIBUTED for Conference of 1/10/2025. |
Reply of petitioner A. J. T. filed. (Distributed) |
Reply of petitioner A. J. T. filed. (Distributed) |
Waiver of the 14-day waiting period for the distribution of the petition pursuant to Rule 15.5 filed by petitioners. |
Waiver of the 14-day waiting period for the distribution of the petition pursuant to Rule 15.5 filed by petitioners. |
Brief of respondents Osseo Area Schools, et al. in opposition filed. |
Brief of respondents Osseo Area Schools, et al. in opposition filed. |
Motion to extend the time to file a response is granted in part and the time is extended to and including December 18, 2024. |
Response to motion to extend the time to file a response from petitioner filed. |
Response to motion to extend the time to file a response from petitioner filed. |
Motion to extend the time to file a response from November 18, 2024 to January 17, 2024, submitted to The Clerk. |
Motion to extend the time to file a response from November 18, 2024 to January 17, 2024, submitted to The Clerk. |
Response Requested. (Due November 18, 2024) |
DISTRIBUTED for Conference of 11/1/2024. |
Supplemental brief of petitioner A. J. T. filed. |
Waiver of right of respondent Osseo Area Schools, et al. to respond filed. |
Supplemental brief of petitioner A. J. T. filed. |
Waiver of right of respondent Osseo Area Schools, et al. to respond filed. |
Brief amici curiae of Council of Parent Attorneys and Advocates, et al. filed. |
Brief amici curiae of Council of Parent Attorneys and Advocates, et al. filed. |
Petition for a writ of certiorari filed. (Response due October 7, 2024) |
Petition for a writ of certiorari filed. (Response due October 7, 2024) |