The Supreme Court on June 12 ruled unanimously in favor of an epileptic student who sued a Minnesota school district, alleging that the school illegally denied special accommodations.
The 9–0 opinion in A.J.T. v. Osseo Area Schools was written by Chief Justice John Roberts.
The decision reverses a federal appeals court ruling that rejected the student’s claims under the Americans With Disabilities Act (ADA) and the Rehabilitation Act, which also provides protections for disabled individuals.
The new Supreme Court ruling does not resolve the lawsuit itself but allows the student to move forward with the stalled legal proceeding.
The student, known as A.J.T. and by her first name, Ava, suffers from Lennox-Gastaut Syndrome, a rare kind of epilepsy, according to the family’s petition.
Ava has intellectual limitations and experiences seizures during the day, the petition states. The most severe seizures happen in the morning, but after that, “she’s alert and able to learn until about 6 p.m.” She also needs assistance with walking and toileting, according to the petition.
The family argued in the petition that the school district, in deciding whether accommodations were required, applied a stricter test to the circumstances than was warranted, which would make it more difficult for the family to succeed with a claim.
The family filed suit under several federal statutes, including the Individuals with Disabilities Education Act (IDEA), which guarantees that all children receive a “free appropriate public education.”
Before Ava’s family moved to Minnesota in 2015, her public school district in Kentucky met her needs, including home instruction late in the day. Her new school district in Minnesota, Osseo Area Schools, “refused to accommodate her,” denying evening instruction and giving “a series of shifting explanations,” according to the petition.
In the beginning, the district stated that it did not want to set a bad precedent and then later stated that educating at home “would be too restrictive,” while at the same time saying it needed more “data” to rationalize a “programming change,” the petition states.
In the first three years of living in Minnesota, Ava received two fewer hours of daily instruction than nondisabled students received. Ava’s parents launched an IDEA complaint with the Minnesota Department of Education. An administrative law judge held that the district violated the IDEA. The judge ruled that instead of prioritizing the child’s educational needs, the district was more concerned with maintaining “the regular hours of the school’s faculty.”
The judge directed the district to provide evening instruction.
The school district appealed to the federal district court. At about the same time, Ava’s parents sued the district under the ADA and Rehabilitation Act, asking for an injunction to “permanently secure [Ava]’s rights to a full school day,” along with compensatory damages for the mistreatment she experienced, according to the petition.
The federal district court affirmed the ruling in favor of Ava under the IDEA, finding that she needed “more than 4.25 hours of schooling a day.” The court found that “extending her instructional day until 6 p.m. and including compensatory hours of instruction” was “the appropriate remedy” under the IDEA.
However, the court ruled against Ava with regard to the ADA and Rehabilitation Act claims, reasoning that she had failed to demonstrate that the district acted either with “bad faith or gross misjudgment,” according to the petition.
A panel of the U.S. Court of Appeals for the Eighth Circuit affirmed.
After acknowledging that the family had produced evidence demonstrating that the Minnesota district had been “negligent or even deliberately indifferent” in denying the reasonable accommodations that the Kentucky district provided for years, the panel held that it was “constrained” by the circuit court’s 1982 ruling in Monahan v. Nebraska that created a bad-faith-or-gross-misjudgment standard.
In the Third and Ninth circuits, the evidence that Ava presented would have been strong enough to survive a motion to dismiss, but in the Eighth Circuit and four other circuits “embracing Monahan’s uniquely stringent standard,” it wasn’t, the petition states.
In June 2024, the full Eighth Circuit denied a request for rehearing.
Roberts wrote in the Supreme Court’s new ruling that claims made under the ADA and Rehabilitation Act relating to educational services “should be subject to the same standards that apply in other disability discrimination contexts.”
Nothing in the language used in the two statutes “suggests that such claims should be subject to a distinct, more demanding analysis,” he wrote.
Both laws apply to “qualified individuals” with disabilities and there is no indication that the text in the statutes applies “with lesser force to certain qualified individuals bringing certain kinds of claims.”
The problem with the Eighth Circuit’s bad-faith-or-gross-misjudgment standard is that it imposes a higher bar for “claims based on educational services,” as opposed to “other disability-discrimination contexts,” Roberts wrote.
Children with disabilities already “face daunting challenges” and should not have to satisfy a more demanding standard of proof than other plaintiffs to show discrimination under the ADA and the Rehabilitation Act, the chief justice said.
The Supreme Court vacated the judgment of the Eighth Circuit and sent the case back to that court “for further proceedings consistent with this opinion.”
This article by Matthew Vadum appeared June 12, 2025, in The Epoch Times.
Photo: Chief Justice John Roberts