Supreme Court Decides A.J.T. v. Osseo Area Schools, Independent School District No. 279

On June 12, 2025, the U.S. Supreme Court issued a decision in A.J.T. v. Osseo Area Schools, Independent School District No. 279, No. 24–249, holding that schoolchildren bringing discrimination claims under the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act 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.

A.J.T. is a teenage student with a rare form of epilepsy, which made it difficult for her to attend school in the morning but permitted her to attend in the evening. After changing schools in 2015, her new school refused to accommodate her request to receive school instruction in the evening. A.J.T.’s parents filed an Individuals with Disabilities Education Act (IDEA) complaint, and an administrative law judge determined that the school district had violated the IDEA.

A.J.T. subsequently sued the school district for compensatory damages and permanent injunction under the ADA and Rehabilitation Act. The District Court granted summary judgment for the school district. The Eighth Circuit affirmed the District Court’s ruling, and further reasoned that a school district’s failure to provide reasonable accommodation was not enough to state a prima facie case for discrimination. Instead, plaintiffs must prove that a school official’s conduct rises to the level of “bad faith” or “gross misjudgment.”

The Supreme Court vacated the judgment of the Eighth Circuit and remanded for further proceedings, holding that the plain language of the IDEA directs that the IDEA does not limit or restrict the rights or remedies that the ADA and Rehabilitation Act provide to children with disabilities. The Eighth Circuit’s ruling, the Court held, would impose a higher bar for discrimination claims based on educational services than for other sorts of disability discrimination claims. Because such a standard could not be squared with the plain text of the IDEA, the Court concluded that the Eighth Circuit had erred in requiring a showing of either bad faith or gross misjudgment.

Chief Justice Roberts delivered the opinion on behalf of a unanimous Court. Justice Thomas filed a concurring opinion that was joined by Justice Kavanaugh. Justice Sotomayor filed a concurring opinion that was joined by Justice Jackson.