06/12/2025
Protecting the Legal and Civil Rights of Students with Disabilities and their Families
COPAA celebrates a major victory for students with disabilities and their families. The U.S. Supreme Court ruled 9-0 on June 12, 2025 in A.J.T. v. Osseo Area Schools in favor of the family of a student with a disability, holding that “ADA and [Section 504] Rehabilitation Act claims based on educational services should be subject to the same standards that apply in other disability discrimination contexts.” Thanks to today’s ruling, students with disabilities and their families bringing civil rights claims against their school districts for disability discrimination will no longer have to meet the uniquely high and burdensome standard of proving that school officials acted with bad faith or gross misjudgment. This high standard has been applied by several circuit courts of appeals over the last four decades.
As the Court explained this morning, “…20 U. S. C. §1415(l), 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 disabled children’s rights. This provision makes clear that the IDEA does not restrict or limit rights or remedies that other federal antidiscrimination statutes independently confer on children with disabilities. The bad faith or gross misjudgment rule… is irreconcilable with the unambiguous directive of §1415(l). In imposing a higher bar for discrimination claims based on educational services as compared to other sorts of disability discrimination claims, the Eighth Circuit effectively read the IDEA to implicitly limit the ability of disabled schoolchildren to vindicate their independent ADA and Rehabilitation Act rights, thereby making it more difficult to secure the statutory remedies provided by Congress.”
As for what standard should apply going forward, the Court noted that per the “general approach” of the federal circuit courts of appeals for disability discrimination claims in other contexts, plaintiffs bringing ADA and Section 504 claims can obtain injunctive relief without proving intent to discriminate. Meanwhile, plaintiffs seeking compensatory damages typically must show “deliberate indifference,” requiring a plaintiff to prove that “the defendant
disregarded a ‘strong likelihood’ that the challenged action would ‘result in a violation of federally protected rights.’”
COPAA congratulates our member Amy J. Goetz, founder of the School Law Center in Minnesota, who represented the family in this case, as well as Roman Martinez of Latham & Watkins, LLP, who argued the case before the U.S. Supreme Court.
As COPAA and its fellow amici established in an amicus brief submitted to the Court in support of the family’s argument, “under the appropriate standard—the standard applicable to everyone outside the K-12 school setting,” countless schoolchildren alleging disability discrimination “would have been compensated for the harms caused by the discrimination that Section 504 and the ADA seek to remedy.”
We applaud today’s decision, which marks a legal sea change for many children who have been subject to disability-based discrimination in school.
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