“One Standard for All” – The Supreme Court Abolishes the “Bad-Faith or Gross-Misjudgment” Hurdle in ADA & §504 Education Cases

Introduction

In A. J. T. v. Osseo Area Schools, Indep. Sch. Dist. No. 279, 605 U.S. ___ (2025), the Supreme Court unanimously dismantled a four-decade-old doctrine that had made disability-discrimination claims in the elementary and secondary school setting uniquely difficult to win. The litigation began when A. J. T., a Minnesota student with severe, seizure-inducing epilepsy, was denied evening classroom hours that her medical condition required. After prevailing under the Individuals with Disabilities Education Act (IDEA) in administrative and judicial proceedings, A. J. T. sued the district again—this time under Title II of the Americans with Disabilities Act (ADA) and §504 of the Rehabilitation Act—seeking damages and injunctive relief.

The Eighth Circuit applied its long-standing rule from Monahan v. Nebraska, 687 F.2d 1164 (8th Cir. 1982), requiring proof that school officials acted with “bad faith or gross misjudgment.” The Supreme Court granted certiorari to decide whether that heightened intent requirement may constitutionally or statutorily apply only to school-related ADA/§504 claims.

Summary of the Judgment

Chief Justice Roberts, writing for a unanimous Court, vacated the Eighth Circuit’s judgment. The Court held that:

“Bad faith or gross misjudgment” is not a prerequisite to liability in ADA or §504 suits that challenge educational services.
ADA and §504 actions brought by K-12 students must be evaluated under the same intent standards that govern disability-discrimination suits in any other context.
The asymmetric standard created by Monahan conflicts with 20 U.S.C. §1415(l), which expressly preserves parallel federal remedies outside the IDEA.
The Court declined the school district’s invitation to extend “bad faith or gross misjudgment” to all ADA/§504 cases, finding that question outside the grant of certiorari.

Analysis

1. Precedents Cited and Their Influence

Monahan v. Nebraska (8th Cir. 1982) – Source of the “bad-faith or gross-misjudgment” rule. The Court explicitly repudiated its logic.
Smith v. Robinson, 468 U.S. 992 (1984) – Earlier harmonization attempt that made IDEA the exclusive remedy. Congress reversed Smith in 1986 by adding §1415(l).
Fry v. Napoleon Community Schools, 580 U.S. 154 (2017) – Clarified the overlap between IDEA and other disability statutes; cited to emphasize Congressional intent embodied in §1415(l).
Decisions establishing the ordinary ADA/§504 standards: Hall v. Higgins (8th Cir. 2023), Midgett v. Tri-County Metro (9th Cir. 2001), S.H. v. Lower Merion (3d Cir. 2013)—all recognize no-intent liability for injunctive relief and “deliberate indifference” for damages.

2. The Court’s Legal Reasoning

The opinion follows a straightforward textual and structural path:

Plain Text – Title II and §504 apply to “any qualified individual” and provide remedies to “any person” without carve-outs for schoolchildren. Nothing in either statute suggests a special educational carve-out.
Statutory Harmony via §1415(l) – Congress repudiated Smith by guaranteeing that IDEA does not limit other disability rights. A heightened school-only standard would defeat that guarantee.
Rejecting Judicial Policymaking – Monahan’s “balancing” rationale is policy-driven and unmoored from statutory text; the Court stresses that it is not the judiciary’s role to add hurdles absent congressional instruction.
Narrow Holding – Because the District changed its litigation theory mid-stream (asking to universalize the higher standard), the Court confines its ruling to abolishing the education-specific hurdle and refuses to define the general intent threshold (leaving lower courts’ “no intent / deliberate indifference” framework undisturbed).

3. Likely Impact of the Decision

Immediate Litigation Consequences – Pending and future student ADA/§504 suits in circuits that applied Monahan-style tests (8th, 6th, 10th, 11th in part) will be reopened or decided under ordinary intent rules. Summary-judgment victories for schools based solely on lack of “gross misjudgment” are vulnerable.
Standardization Nationwide – The ruling brings doctrinal uniformity: K-12 disability claims now track the standards used for public transportation, prisons, voting access, and every other Title II/§504 setting.
Strategic Choices for Plaintiffs – Families may pursue ADA/§504 claims in tandem with IDEA claims more confidently, particularly to seek compensatory damages (unavailable under IDEA itself, per Luna Perez v. Sturgis Public Schools, 598 U.S. 142 (2023)).
Policy and Fiscal Pressure on Schools – Districts must reevaluate accommodation practices; failure to implement feasible adjustments now risks damages rather than only injunctive orders.
Future Supreme Court Agenda – Justices Thomas and Sotomayor penned concurrences signaling potential scrutiny of the prevailing “deliberate indifference” standard and Spending Clause questions. Expect test cases challenging the intent threshold for all ADA/§504 litigation.

Complex Concepts Simplified

IDEA vs. ADA/§504 – IDEA is a funding statute promising a customized education (via an Individualized Education Program or “IEP”). ADA and §504 are broad civil-rights laws banning disability discrimination in public entities and federally funded programs.
§1415(l) – A provision stating that nothing in IDEA cancels other federal disability rights, but plaintiffs must first exhaust IDEA’s administrative process if they seek overlapping relief.
Bad Faith or Gross Misjudgment – A severe blameworthiness standard akin to proof of almost intentional wrongdoing; it asked whether officials deliberately ignored expert advice, acted recklessly, or were plainly incompetent.
Deliberate Indifference – The mainstream intent standard for damages: the defendant knew facts making violation of rights likely and consciously disregarded that risk.
Slip Opinion – The Court’s preliminary version of its opinion; pagination and wording can change before publication in the U.S. Reports.

Conclusion

A. J. T. v. Osseo closes a 40-year chapter in which students with disabilities bore a heavier evidentiary burden than any other class of ADA or §504 plaintiffs. By reading the statutes as written—and by giving full force to Congress’s 1986 directive in §1415(l)— the Court realigns disability law with ordinary principles of statutory interpretation and with the broad remedial purposes Congress articulated. The decision substantially strengthens civil-rights protections for students with disabilities and foreshadows renewed debates over what level of intent, if any, should ever be required under the ADA and the Rehabilitation Act. For now, school districts across the nation must accommodate disabled students under the same rules that govern every other public entity: without discriminatory causation, but free of any special immunity cloak labeled “bad faith or gross misjudgment.”