A.J.T. held that schoolchildren bringing ADA and Rehabilitation Act claims do not have to satisfy a special bad-faith-or-gross-misjudgment standard just because their claims concern education. The ruling reversed the Eighth Circuit's heightened standard and returned the case for ordinary disability-discrimination analysis.
A.J.T. has a severe form of epilepsy that made it hard for her to attend school in the morning. Her family sought evening instruction after moving to Minnesota. Lower courts applied a heightened standard that required proof of bad faith or gross misjudgment by the school district.
May courts impose a heightened bad-faith-or-gross-misjudgment standard on ADA and Rehabilitation Act claims brought by students with disabilities in education settings?
Students bringing ADA and Rehabilitation Act claims related to education are subject to the same standards that apply in other disability-discrimination contexts, not a special bad-faith-or-gross-misjudgment standard.
How the justices lined up in this decision.
The ruling matters for disabled students and families because it removes a special barrier to damages and discrimination claims against schools. It does not guarantee victory for A.J.T. or any future plaintiff. It means courts must judge education-related disability claims under the same standards used in other ADA and Rehabilitation Act settings.
Chief Justice Roberts wrote for a unanimous Court. Justice Thomas concurred, joined by Justice Kavanaugh. Justice Sotomayor concurred, joined by Justice Jackson.