Supreme Court Clarifies Disability Discrimination Standards in Education

by Joseph Miller and Nehal Kaur

The United States Supreme Court’s recent decision in A.J.T. v. Osseo Area Schools addressed the standards governing disability discrimination claims in the educational context under federal law. The ruling resolves a split among lower courts by rejecting a heightened evidentiary standard that some jurisdictions had required plaintiffs to meet when bringing claims under the Americans with Disabilities Act (“ADA”) and Section 504 of the Rehabilitation Act.

The case arose from a dispute involving a student with a disability and a school district’s response to a requested accommodation. A.J.T. was a student with a severe form of epilepsy that prevented her from attending school during standard morning hours, though she was able to participate later in the day. Her previous school district accommodated her condition by modifying her instructional schedule. After transferring to a new district, her parents requested similar accommodations, including instruction later in the day to provide her with an educational experience comparable to that of other students.

The school district denied that request and instead offered a shortened school day. As a result, A.J.T. received approximately 4.25 hours of instruction per day, whereas her peers received 6.5 hours.

A.J.T.’s parents pursued multiple avenues of relief. They filed claims under Title II of the ADA and Section 504 of the Rehabilitation Act, seeking damages and other remedies. They also initiated administrative proceedings under the Individuals with Disabilities Education Act (“IDEA”). An administrative law judge determined that the district had violated the IDEA and ordered compensatory education and additional services. That ruling was later upheld in federal court.

The ADA and Rehabilitation Act claims, however, were dismissed by the lower courts. Relying on appellate court precedent, the court applied a heightened standard requiring plaintiffs in education-related disability cases to demonstrate that school officials acted with “bad faith or gross misjudgment.” Under that framework, a failure to provide a requested accommodation was insufficient to establish liability by itself.

The Supreme Court rejected that view. In its opinion, the Court concluded that neither the ADA nor the Rehabilitation Act supports imposing a different or heightened standard of proof simply because a disability discrimination claim arises in an educational setting. The Court explained that both statutes apply broadly and contain no language suggesting that schools should be treated differently from other public entities subject to the same antidiscrimination requirements.

The Court also addressed the relationship between the ADA and the IDEA. While the IDEA provides a detailed framework governing special education services, the Court emphasized that it does not displace or narrow the scope of protections available under the ADA or Section 504. According to the Court, the existence of IDEA remedies does not justify raising the threshold for liability under other federal disability statutes.

As a result of the decision, plaintiffs bringing disability discrimination claims against educational institutions are subject to the same standards that apply in other ADA and Rehabilitation Act cases. A showing that a qualified individual with a disability was denied meaningful access to a public program or service may be sufficient, without the additional requirement of proving bad faith or gross misjudgment by school officials.

The ruling will undoubtedly affect how disability discrimination claims in education are litigated and evaluated going forward. Following A.J.T., federal disability discrimination laws will not apply differently in the education setting. For students and families, the case clarifies the legal standard applicable to claims seeking relief under the ADA and Section 504. For school districts and other educational institutions, the decision underscores the importance of careful consideration and documentation when responding to accommodation requests.