A. J. T., by and Through Her Parents, A. T., et al. v. Osseo Area Schools, Independent School District No. 279, et al.
No. 24-249 · Decided June 12, 2025 · vacated and remanded
Whether schoolchildren bringing claims under Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act related to their education must satisfy a heightened showing of "bad faith or gross misjudgment." The Court considers if this higher bar is required specifically in the educational context compared to other disability discrimination contexts. Schoolchildren bringing ADA and Rehabilitation Act claims related to their education are subject to the same standards as other disability discrimination contexts, rather than a heightened "bad faith or gross misjudgment" standard.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT · Argued April 28, 2025
Parties — Petitioner: A. J. T., by and through her parents, A. T., et al. · Respondent: OSSEO AREA SCHOOLS, INDEPENDENT SCHOOL DISTRICT NO. 279, et al.
Vote & lineup9–0 (unanimous) on the judgment. Roberts delivered the opinion for a unanimous Court (9). Concurrence(s): Thomas (joined by Kavanaugh); Sotomayor (joined by Jackson).
Who prevailed — Petitioner A. J. T. prevailed on the issue of whether she must satisfy a heightened intent standard to pursue her ADA and Rehabilitation Act claims.
The question

Whether schoolchildren bringing claims under Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act related to their education must satisfy a heightened showing of "bad faith or gross misjudgment." The Court considers if this higher bar is required specifically in the educational context compared to other disability discrimination contexts. It further examines whether such a standard is compatible with the Individuals with Disabilities Education Act (IDEA).

Petitioner's argument
  • Argued that the Eighth Circuit's "bad faith or gross misjudgment" rule is an arbitrary departure from the more lenient standards applied to ADA and Rehabilitation Act claims outside of school settings.
  • Sought a ruling that schoolchildren should be subject to the same legal standards as any other plaintiff seeking relief under these disability discrimination statutes.
  • Contended that the heightened standard effectively limits the ability of disabled children to vindicate independent statutory rights and secure remedies provided by Congress.
Respondent's argument
  • Initially relied on *Monahan v. Nebraska* to argue that a higher intent standard was necessary to "harmonize" the Rehabilitation Act with the IDEA and balance the rights of children against the responsibilities of school officials.
  • Later argued that "bad faith or gross misjudgment" is the correct standard for all ADA and Rehabilitation Act claims, whether they occur in schools or other contexts.
  • Contended that the plain text of the underlying statutes prohibits only intentional discrimination.
The decision
  • Held that schoolchildren 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 are subject to the same standards as other disability discrimination contexts.
  • Reasoned that the plain terms of Title II of the ADA (42 U.S.C. § 12132) and Section 504 of the Rehabilitation Act (29 U.S.C. § 794(a)) apply to "qualified individuals" without any textual indication that protections are lesser for certain types of claims.
  • Noted that remedial provisions in 29 U.S.C. § 794a(a)(2) and 42 U.S.C. § 12133 make rights available to "any person" without distinction or limitation, citing *SAS Institute Inc. v. Iancu*.
  • Determined that the "bad faith or gross misjudgment" rule derived from *Monahan v. Nebraska* is irreconcilable with the unambiguous directive of 20 U.S.C. § 1415(l).
  • Cited 20 U.S.C. § 1415(l), which explicitly provides that nothing in the IDEA "shall be construed to restrict or limit the rights, procedures, and remedies available under" the ADA, Rehabilitation Act, or other federal laws protecting children with disabilities.
  • Concluded that by imposing a higher bar for educational services, the Eighth Circuit effectively read the IDEA as implicitly limiting the ability of disabled schoolchildren to vindicate independent statutory rights.
  • Declined to rule on respondent's broader argument that "bad faith or gross misjudgment" should apply across the board because the issue was not resolved below and was outside the question presented, citing *Glover v. United States* and *Norfolk Southern R. Co. v. Sorrell*.
Separate opinions
Thomas, concurring (joined by Kavanaugh)
  • Argues that in a future appropriate case, the Court should consider whether intent is required to establish any violation or obtain any relief under Title II and Section 504.
  • Invokes Spending Clause principles from *Barnes v. Gorman* and *Pennhurst State School and Hospital v. Halderman*, arguing that conditions on federal funds must be unambiguous.
  • Raises constitutional concerns regarding the Commerce Clause (*United States v. Lopez*), the Fourteenth Amendment (*Board of Trustees of Univ. of Ala. v. Garrett*), and anti-commandeering principles (*Murphy v. National Collegiate Athletic Assn.*).
Sotomayor, concurring (joined by Jackson)
  • Argues that the statutes do not require "improper purpose" or "animus," as the phrase "by reason of" denotes a causal relationship per *Husted v. A. Philip Randolph Institute* and *University of Tex. Southwestern Medical Center v. Nassar*.
  • Cites *Alexander v. Choate* to argue that discrimination against the handicapped is often the product of "benign neglect" or "thoughtlessness" rather than invidious animus.
  • Points to affirmative obligations for reasonable accommodations found in 42 U.S.C. § 12131(2), 42 U.S.C. § 12201(h), and 29 U.S.C. § 794(c).
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