A.J.T. v. Osseo Area Schools

A.J.T. is a teenage girl with a rare form of epilepsy (Lennox-Gastaut Syndrome) that causes severe morning seizures, preventing her from attending school before noon. After moving to Minnesota in 2015, her school district, Osseo Area Schools, denied her parents' requests to include evening instruction in her Individualized Educational Program (IEP), resulting in her receiving only 4.25 hours of daily instruction compared to the typical 6.5-hour school day. Her parents filed an IDEA complaint, and an Administrative Law Judge ruled in their favor, ordering compensatory education and evening instruction. They then sued under the ADA and Rehabilitation Act for damages, but the District Court and Eighth Circuit granted summary judgment for the school, requiring proof of "bad faith or gross misjudgment." The Supreme Court granted certiorari and issued a unanimous decision on June 12, 2025.

The Supreme Court held that schoolchildren are not required to make a heightened showing of bad faith or gross misjudgment and are subject to the same standards as in other disability discrimination contexts. The Court vacated the Eighth Circuit's judgment and remanded the case for further proceedings. The decision was unanimous (9-0), with an opinion by Chief Justice John Roberts, and concurring opinions by Justice Thomas (joined by Kavanaugh) and Justice Sotomayor (joined by Jackson).

Whether students with disabilities bringing discrimination claims under the ADA and Rehabilitation Act related to their education must satisfy a heightened "bad faith or gross misjudgment" standard, or are subject to the same standards that apply in other disability discrimination contexts.

The ruling is a significant victory for students with disabilities, eliminating an unfair legal barrier that required them to prove malicious intent to win discrimination cases. It aligns education-related disability claims with other discrimination contexts, reinforcing that discrimination resulting from indifference or carelessness is also illegal. This decision, along with prior rulings like Fry v. Napoleon and Perez v. Sturgis, strengthens the civil rights protections for students with disabilities under the ADA and Section 504.