06-17-2025
A.J.T. is a student who suffers from seizures and needs help with everyday tasks. She has fewer seizures in the afternoon. Her school accommodated her by providing instruction primarily in the afternoon and into the evening. Then, A.J.T.’s family moved into a new school district in a new state. Osseo Area Public Schools denied her parents’ requests for evening instruction. As a result, her school day was shorter than that of her classmates. When A.J.T. started middle school, the school district cut back the length of her instruction even further and refused requests to give her comparable hours to her peers. A.J.T. and her parents sued the school district.
The trial court stated that A.J.T. is a “qualified individual with a disability” who “was denied the same length school days as her nondisabled peers based on her disability.” However, the court concluded that A.J.T. did not state a prima facie case under Section 504 of the Rehabilitation Act or the ADA because she did not demonstrate that the school district “acted with bad faith or gross misjudgment.” The Eighth Circuit Court of Appeals affirmed the lower court’s decision. The appellate court asserted that A.J.T. had to show more than “mere non-compliance.” The court noted that this standard is higher than what is needed for other disability discrimination claims.
The U.S. Supreme Court, with Chief Justice Roberts writing the unanimous opinion, held that ADA and Rehabilitation Act claims based on educational services should be subject to the same standards as apply in other disability discrimination claims. Both statutes provide relief to “any person” and are “expansive and unqualified.” Disabled students must show only that the school system acted with “deliberate indifference.” A.J.T.’s case was remanded to the lower courts so that she may proceed.
