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A. J. T., by and through her parents, A. T. et al. v. Osseo Area Schools, Independent School District

No. 24–249, 605 U.S. 335 (2025).
U.S. Supreme Court
June 12, 2025

Keywords: education, Title II of the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act, Individuals with Disabilities Education Act (IDEA), Individualized Educational Program (IEP), epilepsy, reasonable accommodations, remedies.

Summary

Section 504 of the Rehabilitation Act (Section 504), Title II of the Americans with Disabilities Act (ADA), and the Individuals with Disabilities Education Act (IDEA) all work together to protect school children with disabilities. Section 504 and the ADA prevent disability discrimination broadly. The IDEA specifically provides children with disabilities essential education services.

The IDEA allows for making “individualized education plans” (IEP). An IEP is a personalized plan designed to meet the educational needs of a child with a disability. To create an IEP, a child’s parents, teachers, and other school officials work together to determine necessary accommodations.

Sometimes, a child’s parents, teachers, and other school officials will disagree on what should be included in an IEP. When this happens, the IDEA has a formal way to address the disagreement. First, a local or state education agency will review the plan. Second, if both sides still disagree, a lawsuit may be brought in either state or federal court.

Before A.T. et.al. v. Osseo Area School District, several circuit courts believed that families bringing disability discrimination suits faced a higher standard to prove that they had been discriminated against more than other litigants under Section 504 and the ADA. Still, other circuit courts believed that children bringing disability discrimination suits had to show the same level of proof required for other litigants under Section 504 and the ADA. Because of this split between the circuit courts, the Supreme Court agreed to take this case to decide what standard of proof governed disability discrimination claims involving children. In the end, the Court unanimously ruled that claims brought by children and their families regarding educational discrimination should have the same standards of proof that apply in other discrimination contexts. The Court ultimately set aside the lower court judgment and sent the case back to the lower courts.

Facts of the Case

A.J.T. is a teenage girl who has a rare form of epilepsy. A.J.T.’s epilepsy caused her to have seizures throughout the day that created safety concerns and affected with her ability to learn. Her seizures were so frequent in the morning that she could not go to school before noon. From noon until 6 p.m., A.J.T. had fewer seizures and was able to attend school and receive at-home instruction.

During her first years of school in Kentucky, A.J.T.’s parents and teachers allowed her to avoid activities before midday, and later to receive at-home instruction. Then, A.J.T. and her family moved to Minnesota. The new school district denied her parents repeated requests to provide A.J.T. with at-home schooling as documented by her IEP. When they realized that agreement was impossible, A.J.T.’s parents filed an IDEA complaint with the Minnesota state department of education. After a five-day hearing, the department of education concluded that the school district had violated IDEA.

The school district filed a lawsuit claiming that the department of education’s conclusion was wrong. A.J.T. won, then the school district appealed to a higher court, and A.J.T. won again.

After that, A.J.T. and her parents sued the school district and the school board under Title II of the ADA and Section 504. A.J.T. and her parents sought an injunction (a court order that makes a party to perform or refrain from a specific action), pay the family back for certain costs, and they asked for money damages. A.J.T. lost initially, and after she appealed, A.J.T. lost again. In both cases, the court said that A.J.T. had could not prove that the school district violated her IEP due to “bad faith or gross misjudgment”—an unusually high standard of proof.

A.J.T. and her parents appealed again to the United States Supreme Court and the Court agreed to hear the case.

Issues of the Case

  1. Do children with disabilities seeking relief for education-related discrimination have a higher legal test than all other plaintiffs suing under Title II of the ADA and Section 504 of the Rehabilitation Act?

Arguments and Analysis

1. Do children with disabilities seeking relief for education-related discrimination have a higher legal test than all other plaintiffs suing under Title II of the ADA and Section 504 of the Rehabilitation Act?

Writing for a unanimous Court, meaning every justice sided with A.J.T., Chief Justice Roberts began by noting that the “general approach” developed by the lower courts outside the education context did not require a showing of proof as high as that required in education cases.

Turning to the exact question in the case, Chief Justice Roberts wrote that claims based on disability in education cases should not have a higher standard of proof. Chief Justice Roberts noted that nothing in Title II of the ADA or Section 504 suggested that claims brought under those laws based on disability discrimination in education should face a higher bar of proof. Chief Justice Roberts recognized how the lower courts had come to believe that a higher standard of proof for children with disabilities in schools was necessary. But he rejected this reasoning and said that Congress itself had added a section to the anti-discrimination statutes saying that nothing “shall be construed to restrict or limit” available relief

Rulings

School children bringing education discrimination claims under Title II of the ADA or Section 504 do not have to meet a higher standard to prove their claim. Instead, such claims are subject to the same standards of proof that apply in other disability contests.

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These materials do not constitute legal advice and should not be relied upon in any individual case. Please consult an attorney licensed in your state for legal advice and/or representation. These materials were prepared by the legal research staff of the Burton Blatt Institute (BBI) at Syracuse University in partnership with the Southeast ADA Center to highlight legal and policy developments relevant to civil rights protections and the impact of court decisions in the Southeast Region under the Americans with Disabilities Act (ADA). These materials are based on federal disability rights laws and court decisions in effect at the time of publication. Federal and state disability rights law can change at any time.  In addition, state and local laws and regulations may provide different or additional protections. Materials are intended solely as informal guidance, and are neither a determination of your legal rights nor responsibilities under the ADA or other federal, state, and local laws, nor binding on any agency with enforcement responsibility under the ADA. The accuracy of any information contained herein is not warranted. Any links to external websites are provided as a courtesy and are not intended to nor do they constitute an endorsement of the linked materials.

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