The question
Whether schoolchildren bringing claims under the Americans with Disabilities Act and the Rehabilitation Act related to their education must meet a heightened "bad faith or gross misjudgment" standard rather than the standards applied in other disability discrimination contexts.
A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279
What the Court decided
Reversed. The Court held that schoolchildren bringing ADA and Rehabilitation Act claims related to their education do not have to make a heightened showing of "bad faith or gross misjudgment" and instead are subject to the same standards that apply in other disability discrimination contexts. Nothing in the text of Title II of the ADA or Section 504 of the Rehabilitation Act suggests that education-based claims should face a distinct, more demanding analysis. The decision was unanimous.
How the justices split
UnanimousThe Court's opinion
Roberts, joined by Thomas, Alito, Sotomayor, Kagan, Gorsuch, Kavanaugh, Barrett, Jackson
Neither the substantive protections nor the remedial provisions of Title II of the ADA or Section 504 of the Rehabilitation Act supports subjecting education-based claims to a distinct, more demanding standard. The heightened 'bad faith or gross misjudgment' rule traced to the Eighth Circuit's 1982 Monahan decision, which sought to harmonize the Rehabilitation Act with the IDEA, but nothing in the statutory text calls for it. Schoolchildren bringing these claims are subject to the same standards that apply in other disability discrimination contexts.
Concurring
Thomas, joined by Kavanaugh
Thomas filed a concurring opinion, joined by Kavanaugh. The syllabus identifies the opinion and its joiner but does not state its reasoning.
Concurring
Sotomayor, joined by Jackson
Sotomayor filed a concurring opinion, joined by Jackson. The syllabus identifies the opinion and its joiner but does not state its reasoning.
How we know · 5 sourced claims
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.
Source: syllabus, Held
Such education-based claims are subject to the same standards that apply in other disability discrimination contexts.
Source: syllabus, Held
The heightened bad faith or gross misjudgment standard traces to the Eighth Circuit's 1982 decision in Monahan, which reasoned it was necessary to harmonize the Rehabilitation Act and the IDEA.
Source: syllabus, Held
Chief Justice Roberts delivered the opinion for a unanimous Court.
Source: syllabus, lineup
Thomas filed a concurring opinion joined by Kavanaugh, and Sotomayor filed a concurring opinion joined by Jackson.
Source: syllabus, lineup