In a unanimous decision on June 12, 2025, the U.S. Supreme Court ruled in favor of A.J.T., a teenage girl with a form of epilepsy, against the Osseo Area School District in Minnesota. The Court's ruling rejected a higher “bad faith or gross misjudgment” standard that has been applied to disability cases in K-12 education, but not in other ADA or Rehabilitation Act contexts. This ruling will make educational institutions more vulnerable to damages claims in IDEA cases. 

Background

The plaintiff's epilepsy caused severe morning seizures, which prevented her from attending school before noon. Her parents requested afternoon and evening instruction, which she had received at her prior school. This request was denied and for several years she received 2.25 fewer hours of instruction each day than her peers.  When the plaintiff was to start middle school, the school district proposed further cuts to the plaintiff’s instructional time.  The plaintiff’s family filed a lawsuit alleging violations of the Individuals with Disabilities Education Act (IDEA), Section 504 of the Rehabilitation Act, and the Americans with Disabilities Act (ADA).

The plaintiff prevailed in the IDEA claim, the district court dismissed the discrimination claims under the ADA and Rehabilitation Act, citing the Eighth Circuit's requirement to prove "bad faith or gross misjudgment" by school officials—a higher standard than typically applied in disability discrimination cases. The Eighth Circuit affirmed this decision.

Supreme Court's Decision

The Supreme Court overturned the lower courts' rulings, rejecting the "bad faith or gross misjudgment" standard as overly stringent and inconsistent with the ADA and Rehabilitation Act. The Court emphasized that these statutes require public entities to provide "meaningful access" to their services, which often necessitates reasonable accommodations for individuals with disabilities.

By eliminating the heightened standard, the Court's decision makes it easier for students with disabilities to challenge school districts that fail to provide necessary accommodations. This ruling aligns with the intent of federal disability laws to ensure equal educational opportunities for all students.

Implications

This decision lowers the standard for establishing IDEA liability in those circuits that had adopted the “bad faith or gross misjudgment” standard.  This decision will make school districts more vulnerable to claims that they have not met their obligations under federal law to accommodate the needs of students with disabilities.