Supreme Court Decision Reshapes Disability Rights Landscape in Public Schools
On June 12, 2025, the U.S. Supreme Court issued a unanimous 9–0 decision in A.J.T. v. Osseo Area Schools, Independent School District No. 279, No. 24–249, significantly impacting how students with disabilities can pursue discrimination claims under Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act.
The Court held that students alleging disability discrimination in education under the ADA or Rehabilitation Act are not required to show “bad faith or gross misjudgment.” Instead, they are subject to the same legal standards that apply in other disability discrimination contexts.
A.J.T., a student with a rare form of epilepsy, experiences frequent morning seizures and is only able to attend school in the afternoon and evening. Her previous school district accommodated her with evening instruction, but after moving to Osseo Area Schools (Minnesota) in 2015, the district refused to provide instruction after noon. As a result, A.J.T. received only 4.25 hours of instruction per day, compared to the 6.5-hour day for nondisabled peers. The district later proposed further reductions in her instructional time, prompting her parents to file a complaint under the Individuals with Disabilities Education Act (IDEA).
A.J.T. prevailed on her IDEA claims, with an administrative law judge and subsequent federal courts finding that the district had denied her a Free Appropriate Public Education (FAPE). Following that victory, her family pursued additional claims under the ADA and Rehabilitation Act, arguing that the district’s refusal to accommodate her schedule constituted disability-based discrimination.
The Supreme Court clarified that the IDEA does not limit or heighten the burden for pursuing claims under the ADA or Rehabilitation Act. These statutes are independent civil rights laws, and students do not lose their broader protections simply because they are also covered by the IDEA.
The Court rejected the argument that plaintiffs must show “bad faith or gross misjudgment” in education-related discrimination claims, reaffirming that standard antidiscrimination principles apply—just as they would in employment, housing, or public accommodations.
Implications for Schools:
- Lower threshold for plaintiffs: Students and parents can now bring disability discrimination claims without proving intent or egregious misconduct.
- Increased litigation risk: Schools must ensure that accommodations and services are equitably provided and well-documented.
- Review IEP and 504 practices: Districts should reassess how they handle requests for nontraditional accommodations, such as evening instruction, and ensure compliance with both IDEA and Section 504.
The decision can be access via this link: Read the full opinion.
If you have any questions or concerns, please contact our Education Attorneys.