In A.J.T. v. Osseo Area Schools (Docket 24-249), the Supreme Court recently addressed a significant disability-rights issue. A.J.T., a Minnesota teenager diagnosed with severe epilepsy, experiences incapacitating morning seizures. From 2015 onward, her school district denied her parents’ request to schedule Individualized Educational Program (IEP) sessions in the afternoon or evening, compelling her to truncate her school day to just 4.25 hours—well below the typical 6.5-hour academic day.
When the district proposed further curtailment of instructional time, A.J.T.’s parents initiated proceedings under the IDEA, arguing the refusal violated her right to a free appropriate public education. An administrative law judge, followed by the district court and the Eighth Circuit, agreed and ordered compensatory remedies as well as evening instruction.
However, A.J.T.’s subsequent ADA and Rehabilitation Act claims encountered obstacles. Lower courts granted summary judgment to the district, imposing a higher standard requiring proof of “bad faith or gross misjudgment” by school officials.
The Supreme Court rejected this elevated threshold, holding that ADA and Rehabilitation Act standards in education mirror those in other discrimination contexts. Plaintiffs need not prove malicious intent—only discriminatory impact rooted in disability—to establish liability. The Court vacated the Eighth Circuit’s ruling and remanded for proceedings consistent with this clarified standard.
Violations included claims under Section 504 of the Rehabilitation Act, Title II of the Americans with Disabilities Act, and IDEA (via administrative proceedings).
Key takeaway: School districts cannot avoid ADA or Rehabilitation Act scrutiny by asserting benign intent. Students with disabilities need only demonstrate that school practices result in unequal access—not that officials acted vindictively. This decision safeguards equitable educational opportunity, reaffirming substance over form.
