A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279
View Official PDFBelow are plain-language sections to help you understand what the Court decided in A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279 and why it matters. Quotes are taken from the syllabus (the Courtās short summary at the start of the opinion).
Summary
A short, plain-English overview of A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279.
The Supreme Court addressed whether children with disabilities must meet a heightened standard of proof for discrimination claims under the ADA and Rehabilitation Act. The Court vacated the Eighth Circuit's decision, which required a showing of 'bad faith or gross misjudgment' for such claims in the educational context. The Court clarified that these claims should be subject to the same standards as other disability discrimination contexts.
Holding
The single most important ābottom lineā of what the Court decided in A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279.
The Court held that schoolchildren bringing ADA and Rehabilitation Act claims related to their education are not required to make a heightened showing of 'bad faith or gross misjudgment.'
Constitutional Concepts
These are the Constitution-related themes that appear in A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279. Click a concept to see other cases that involve the same idea.
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Why Equal Protection is relevant to A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279
The case addresses whether children with disabilities must meet a higher standard of proof for discrimination claims under the ADA and Rehabilitation Act, implicating equal protection principles.
Syllabus excerpt (verbatim)Held: Schoolchildren bringing ADA and Rehabilitation Act claims related to their education are not required to make a heightened showing of 'bad faith or gross misjudgment' but instead are subject to the same standards that apply in other disability discrimination contexts.
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Why Procedural Due Process is relevant to A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279
The Court's decision involves the procedural standards required for bringing discrimination claims under the ADA and Rehabilitation Act, which relates to procedural due process.
Syllabus excerpt (verbatim)To obtain compensatory damages, courts generally require a showing of intentional discrimination, which most circuits find satisfied by 'deliberate indifference'āa standard requiring only a showing that the defendant disregarded a strong likelihood that the challenged action would violate federally protected rights.
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Why Spending Power is relevant to A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279
The case involves federal funding conditions under the IDEA, which relates to Congress's spending power.
Syllabus excerpt (verbatim)Beyond these generally applicable antidiscrimination laws, the Individuals with Disabilities Education Act (IDEA), 84 Stat. 175, as amended, 20 U. S. C. Ā§ 1400 et seq., 'offers federal funds to States in exchange for a commitment: to furnish' the core guarantee of a 'free appropriate public education' to all children with certain physical or intellectual disabilities.
Key Quotes
Short excerpts from the syllabus in A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279 that support the summary and concepts above.
Schoolchildren bringing ADA and Rehabilitation Act claims related to their education are not required to make a heightened showing of 'bad faith or gross misjudgment.'
ADA and Rehabilitation Act claims based on educational services should be subject to the same standards that apply in other disability discrimination contexts.
The bad faith or gross misjudgment rule derived from Monahan is irreconcilable with the unambiguous directive of Ā§ 1415(l).
