Docket 24-249
A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279
DecidedJun 12, 2025
9-0decision
Source: CourtListener.
Court strikes down higher legal bar for disability discrimination claims by schoolchildren
Impact6/10
What it does
The Court unanimously struck down a rule used by some federal appeals courts that required students with disabilities to prove school officials acted with "bad faith or gross misjudgment" before their ADA or Rehabilitation Act discrimination claims could proceed. Going forward, students suing schools for disability discrimination must meet the same legal standards as any other person bringing a disability discrimination claim — no higher, no lower. To get an injunction (a court order requiring action), a plaintiff need not prove intentional discrimination; to get money damages, a plaintiff must show the defendant was "deliberately indifferent" to a strong likelihood of violating federally protected rights.
Who benefits
Students with disabilities in public schools, and their parents, who bring discrimination claims under the ADA or Rehabilitation Act when schools fail to provide reasonable accommodations. Children whose disabilities require non-standard scheduling, services, or instructional arrangements benefit most directly.
Who is affected
Public school districts and school boards that receive federal funding and are now subject to the same disability discrimination standards as other public entities, without the protection of the previously higher "bad faith or gross misjudgment" threshold.
Practical impact
Students with disabilities who sue schools under the ADA or Rehabilitation Act can now proceed under the same legal standards used in every other disability discrimination context: no proof of intent is needed to seek a court order requiring accommodation, and proof of "deliberate indifference" — not the much harder "bad faith or gross misjudgment" — is sufficient to seek money damages. The case is sent back to the lower courts for A.J.T.'s claims to be reconsidered under the correct, lower standard. School districts across the country that previously benefited from the heightened standard in the Eighth Circuit and similar circuits will no longer have that extra layer of protection against ADA and Rehabilitation Act suits.
Majority — Roberts
Joined by: Thomas, Sotomayor, Kagan, Gorsuch, Kavanaugh, Barrett, Jackson, Alito
The Court reasoned that nothing in the text of the ADA or the Rehabilitation Act creates a different, harder standard for claims arising in schools — both laws use broad, unqualified language protecting "any" qualified individual with a disability, with no carve-out for the educational context. The heightened "bad faith or gross misjudgment" rule originated in a 1982 Eighth Circuit decision (Monahan v. Nebraska) that tried to "harmonize" the Rehabilitation Act with the Individuals with Disabilities Education Act (IDEA), reasoning that students should have to prove more than a mere failure to provide required services. However, Congress directly rejected that approach when it enacted 20 U.S.C. § 1415(l), which explicitly states that nothing in the IDEA shall restrict or limit the rights and remedies available under the ADA or Rehabilitation Act. The Court held that applying a higher bar to school-based claims effectively reads the IDEA as limiting students' ADA and Rehabilitation Act rights — exactly what Congress said the IDEA must not do. The school district's last-minute argument that "bad faith or gross misjudgment" should be the universal standard for all disability discrimination claims (not just school cases) was declined because it was not the question the Court agreed to hear and had not been argued below.
Constitutional question
Do the Americans with Disabilities Act and the Rehabilitation Act require students with disabilities to meet a stricter legal standard — "bad faith or gross misjudgment" — when suing schools for disability discrimination, compared to the standard that applies in all other disability discrimination cases?
Precedent changed
The ruling effectively invalidates the "bad faith or gross misjudgment" rule from Monahan v. Nebraska, 687 F.2d 1164 (8th Cir. 1982), and its extension to ADA claims, by holding that rule is irreconcilable with 20 U.S.C. § 1415(l). The Court also noted that Congress had already legislatively overturned Smith v. Robinson, 468 U.S. 992 (1984), the Supreme Court precedent on which similar reasoning had been based.