Supreme Court Rejects Heightened Standard of Proof in Disability Discrimination Cases Against Schools

Federal laws, including the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1973, protect people with disabilities from discrimination, including in the area of education.  The Individuals With Disabilities Education Act (IDEA) conditions federal funding to states on the promise to provide a “free appropriate public education” to children with certain disabilities.  Recently, in A.J.T. v. Osseo Area Schools, Indep. School Dist. No. 279, the United States Supreme Court rejected a lower court’s ruling that plaintiffs in education-related cases under the ADA and Rehabilitation Act must show bad faith or gross misjudgment by school officials to recover damages, not just failure to provide a reasonable accommodation as in other discrimination cases.

BACKGROUND OF THE CASE

The plaintiff in A.J.T., identified by her initials because she is a minor, was a teenager who had a rare form of epilepsy with serious manifestations including seizures so severe in the morning hours that she was unable to attend school before noon.  A.J.T. had previously been permitted to attend educational activities in the evening, but after her family relocated, her new school district denied her request for evening education, such that she received significantly less instruction than non-disabled students.  A.J.T.’s parents filed a complaint under the IDEA and won a ruling ordering the district to provide A.J.T. with evening instruction.

A.J.T.’s parents then sued the district under the ADA and Rehabilitation Act, seeking a permanent injunction and compensatory damages.  The federal district court in Minnesota granted summary judgment to the school district and the Eighth Circuit Court of Appeals affirmed the decision.  The appeals court determined that unlike in other discrimination cases under the ADA and Rehabilitation Act, “a plaintiff must prove that school officials acted with ‘either bad faith or gross misjudgment,’ which requires ‘something more’ than mere non-compliance with the applicable federal statutes.’”  Federal appeals courts had disagreed on the appropriate standard, and the Supreme Court accepted the case to resolve the dispute.

WHAT THE SUPREME COURT DECIDED

Writing for a unanimous Supreme Court, Chief Justice John Roberts held unambiguously that “ADA and Rehabilitation Act claims based on educational services should be subject to the same standards that apply in other disability discrimination contexts.”  The Court observed that children with disabilities and their parents “face daunting challenges on a daily basis,” but that “those challenges do not include having to satisfy a more stringent standard of proof than other plaintiffs to establish discrimination under Title II of the ADA and Section 504 of the Rehabilitation Act.”  Chief Justice Roberts noted that the Congress had previously amended the IDEA to overturn caselaw holding that the IDEA was the only mechanism by which a child with a disability could allege that his or her education was inadequate.

WHAT THIS MEANS FOR PARENTS

While the Supreme Court’s decision contains nuances that reflect the complexities of the legal framework it interpreted, A.J.T. makes it clear that the unique challenges that can come with educational accommodations in no way lessen the rights of children with disabilities.  As the varying interpretations of the same law by different courts demonstrate, seeking the law’s protections can be complicated and intimidating.  A lawyer experienced in navigating discrimination claims can help make sure your rights are protected.