## Facts

- A.J.T. is a public-school student with Lennox–Gastaut Syndrome, a severe form of epilepsy whose seizures are most frequent and severe in the morning, preventing her from attending school before noon.
- Before her family moved to Minnesota, a Kentucky public school district provided a schedule roughly from 12:00 p.m. to 6:00 p.m., including evening at-home instruction, giving her instructional time closer to that of nondisabled peers.
- After relocating to Minnesota in 2015, Osseo Area Schools developed an IEP that generally provided instruction from about 12:00 p.m. to 4:15 p.m. (roughly 4.25 hours per day).
- Nondisabled students in the district typically received a school day of about 6.5 hours.
- A.J.T.’s parents repeatedly requested evening instruction or after-hours at-home instruction so that she could receive a day closer in length to that of her peers given her morning seizure pattern.
- The district declined to provide evening instruction, offering other adjustments instead, and cited administrative concerns rather than a pedagogical determination that evening services were unnecessary.
- In 2018, the district proposed further reducing A.J.T.’s school day, and her parents again sought additional after-hours instruction.
- The parents pursued administrative proceedings under the Individuals with Disabilities Education Act (IDEA), alleging denial of a free appropriate public education (FAPE).
- An administrative law judge ruled that the district’s refusal to provide evening instruction denied FAPE and ordered relief that included after-school at-home instruction; federal courts later upheld IDEA relief.
- After prevailing under IDEA, A.J.T. and her parents filed a separate federal suit seeking damages (and related relief) under Title II of the Americans with Disabilities Act (ADA) and § 504 of the Rehabilitation Act, alleging disability discrimination in how educational services were provided.
- The federal district court granted summary judgment to the district, and the Eighth Circuit affirmed, holding that ADA and § 504 education claims required proof of “bad faith or gross misjudgment,” which plaintiffs had not shown.

## Issues

1. Whether Title II of the ADA and § 504 of the Rehabilitation Act require schoolchildren bringing education-related disability-discrimination claims to prove “bad faith or gross misjudgment.”
2. Whether courts may apply a stricter, education-only liability standard to ADA and § 504 claims in light of IDEA and its savings clause, 20 U.S.C. § 1415(l).

## Decision

- The Supreme Court unanimously vacated the Eighth Circuit’s judgment and remanded.
- The Court held that children bringing ADA and § 504 claims related to their education are not required to satisfy a heightened “bad faith or gross misjudgment” standard.
- The Court rejected treating public schools as a special category for ADA/§ 504 liability rules when the statutes’ text and structure supply antidiscrimination protections across settings.
- Relying in part on IDEA’s savings clause, the Court explained that IDEA does not cut back rights and remedies available under the ADA and § 504, and it does not authorize extra judge-made hurdles for education-based discrimination suits.
- The Court did not select a single intent requirement for all ADA and § 504 claims, leaving the lower courts to apply the same generally applicable standards used in other disability-discrimination contexts on remand.

## Legal Principles

- Title II of the ADA and § 504 do not impose an education-specific “bad faith or gross misjudgment” requirement for discrimination claims involving public-school services.
- Courts must apply the same general ADA/§ 504 discrimination framework in the school setting that they apply in other contexts; the governing standard cannot be made stricter simply because the defendant is a school district.
- IDEA’s savings clause, 20 U.S.C. § 1415(l), preserves ADA and § 504 rights and remedies and bars construing IDEA to restrict or limit those protections for children with disabilities.
- When a lower court has applied the heightened “bad faith or gross misjudgment” test to ADA/§ 504 education claims, the proper disposition is vacatur and remand for reconsideration under the correct, generally applicable standard.

## Conclusion

In *A.J.T. v. Osseo Area Schools*, the Supreme Court unanimously ruled that students alleging disability discrimination in educational services under Title II of the ADA and § 504 need not prove “bad faith or gross misjudgment,” a heightened test some courts had reserved for K–12 cases. The Court held that education-related ADA/§ 504 claims are governed by the same standards used in other disability-discrimination settings and that IDEA’s savings clause prevents courts from imposing extra barriers on those claims because they arise in schools. The judgment was vacated and the case remanded for application of the correct standard.


A.J.T. v. Osseo Area Schools, Indep. Sch. Dist. No. 279, 605 U.S. 335 (2025)