Supreme Court Holds that Educational Service Based Claims Filed under the ADA and Section 504 by Disabled Students Should not be Held to a Higher Standard

On June 12, 2025 the Supreme Court issued an important decision deciding the standard of proof a student/family must in order to establish a claim for damages under the Americans With Disabilities Act (“ADA”) or under Section 504 of the Rehabilitation Act alleging that they have been unlawfully denied educational services. In A.J.T. v. Osseo Area Schools, Independent School Dist. No. 279, No. 24-249 (June 12, 2025), the Court held that these educational services claims should be subject to the same standards that apply to other disability discrimination claims – “deliberate indifference” by the school – and are not subject to a heightened standard requiring proof that the school acted with “bad faith or gross misjudgment”.

A.J.T. is a teenage girl who suffers from a rare form of epilepsy that severely limits her physical and cognitive functioning. She requires assistance with everyday tasks like walking and toileting and suffers from seizures throughout the day. Her seizures are so frequent in the morning that she can’t attend school before noon; however, she is alert and able to learn from noon to about 6 p.m.

For the first few years of her schooling, A.J.T.’s parents and educators accommodated her condition by allowing her to avoid activities before midday and to receive evening instruction at home. A.J.T. moved to Minnesota in 2015 and enrolled in the Osseo Area Public Schools. Osseo denied her parents’ accommodation request that under A.J.T.’s IEP she receive evening instruction. After Osseo proposed that the length of A.J.T.’s school day be reduced further A.J.T.’s parents filed a claim alleging that the school’s decision denied A.J.T. a free appropriate public education under the IDEA, 20 U.S.C., § 1400. An administrative law judge determined that the District had violated the IDEA and the District Court and Court of Appeals each affirmed this decision.

A.J.T. and her parents then sued Osseo for damages alleging violations of Title II of the ADA and Section 504 of the Rehabilitation Act. The District Court entered summary judgment against them after ruling that they had failed to satisfy a standard requiring “bad faith or gross misjudgement” and the Court of Appeal affirmed.

The Supreme Court granted certiorari and held that ADA and Section 504 damages claims based on denial of educational services are subject to the same standards that apply in other disability discrimination cases. The Court reasoned that there was no language in either the ADA or Section 504 suggesting that these claims are subject to a different and more demanding level of proof.

The Court pointed to the substantive provisions of both Title II and Section 504, which by their plain terms, apply to “qualified individual[s]” with disabilities. The Court’s analysis found there is no textual indication that the protections of either disability discrimination statute apply with lesser force to certain qualified individuals bringing certain kinds of claims. In other words, the law does not distinguish based on the context in which a claim is brought under either statute.

The Court further explained that there also is nothing in the IDEA, 20 U.S.C. §1415(l), which states that it “shall be construed to restrict or limit the rights, procedures, and remedies available under the Constitution, the ADA, title V of the Rehabilitation Act, including §504, or other Federal laws protecting the rights of children with disabilities, except that before the filing of a civil action under such laws seeking relief that is also available under the IDEA, the IDEA’s administrative procedures shall first be exhausted.” The Court stated that the plain text of §1415(l) makes it clear that a plaintiff who seeks relief available under the IDEA is also entitled to independent ADA and Rehabilitation Act claims for damages.

In summary, where a school district is found to have violated a student’s right to receive educational services under IDEA, a claim for damages under the ADA or Section 504 is subject to the same standard of “deliberate indifference” as applies to other ADA and 504 discrimination claims.

This case is simply another illustration of the care which is required by federal law of school officials in addressing the educational services needs of students with disabilities and the potential consequences of not doing so.

We are pleased to provide legal guidance to school districts in this highly nuanced and complex area of the law.

This update is provided for informational purposes only and should not be considered legal advice.