by Marion M. Walsh, Esq.

On June 12, 2025, the U.S. Supreme Court unanimously ruled in A.J.T. v. Osseo Area Schools that parents of students with disabilities no longer have to prove “bad faith or gross misjudgment” in connection with discrimination claims relating to their education. This is good news for students with disabilities and will make it easier to bring certain discrimination claims. The ruling means that students with disabilities have the right to sue under civil rights laws without having to meet a higher legal standard than other plaintiffs.

Factual Background

The case involves a student with a rare form of epilepsy that severely limited her physical and cognitive functioning. She had seizures that were so frequent in the mornings that she could not attend school before noon, though she was able to learn from noon until 6 p.m. For years, the student’s school district provided instruction in the evening for her. But when the student’s family moved to Minnesota, her school district, the Osseo Area Public Schools, denied her parents’ repeated requests to include evening instruction in her IEP. For three years, the student received only 4.25 hours of instruction daily compared to the typical 6.5-hour school day for nondisabled students in the district. The student’s parents prevailed in a complaint under the Individuals with Disabilities Education Act (IDEA), and federal courts affirmed the IDEA victory. As the claims and harm to the student went beyond the IDEA claims, the parents then sued under the ADA and the Rehabilitation Act, requesting reimbursement for certain costs and compensatory damages. The District Court ruled for the District, and the Eighth Circuit affirmed. The Eighth Circuit stated that a school district’s failure to provide a reasonable accommodation, when combined with an IDEA claim, was not enough to show discrimination, as the prevailing standard required the parents to prove that conduct by school officials rose to the level of bad faith or gross misjudgment. Courts adopted this standard to “balance” or “harmonize” IDEA and Section 504 claims, but the dual standard made it very difficult for parents to prove discrimination claims.

The Supreme Court Ruling

The U.S. Supreme Court reversed the Eighth Circuit ruling. It held that students 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 standard that applies in other disability discrimination contexts – “deliberate indifference.” Justice Roberts recognized specifically that “…children with disabilities and their parents face daunting challenges on a daily basis. We hold today that those challenges do not include having to satisfy a more stringent standard of proof than other plaintiffs to establish discrimination under Title II of the ADA and Section 504 of the Rehabilitation Act.”

What the Case Means for Students with Disabilities

The ruling does not create automatic wins in Section 504 and ADA claims for students as it can still be difficult to show deliberate indifference of school officials, and the IDEA often has more direct and powerful remedies. Yet in cases in which the IDEA and its remedies are not sufficient, such as bullying and harassment claims, the case could have an impact. Talk to an experienced attorney if you think your child has experienced discrimination in school.