Supreme Court Changes the Legal Playing Field for Students with Disabilities

The Court's decision is a watershed moment for school law, with significant implications for school districts

The landmark ruling in the U.S. Supreme Court case A.J.T. v. Osseo Area Schools is likely to increase the volume and scope of disability discrimination claims that K-12 school districts face, making it more critical than ever for districts to reassess their compliance strategies under Section 504 and the Americans with Disabilities Act, write attorneys Ashley A. Akins and Nemonie Nooks.

January 19, 2026

In a unanimous and consequential decision, the U.S. Supreme Court recently recalibrated the legal landscape for students with disabilities and the school districts that serve them. In its June decision in A.J.T. v. Osseo Area Schools, the Court held that students alleging disability discrimination in public education under Section 504 of the Rehabilitation Act and the Americans with Disabilities Act (ADA) are not required to meet a higher bar of proof than plaintiffs in other disability discrimination contexts.

This landmark ruling eliminates the heightened “bad faith or gross misjudgment” standard that had been applied for decades. The decision is likely to increase the volume and scope of disability discrimination claims that K-12 school districts face, making it more important than ever for districts to reassess their compliance strategies under Section 504 and the ADA.

The Case: A Narrow School Day, a Broad Legal Question

The plaintiff, A.J.T., is a teenage student with a form of epilepsy that caused intense and frequent seizures each morning, preventing her from attending school until noon. Despite being alert and able to learn in the afternoon and evening, her school district, Osseo Area Schools in Minnesota, refused to include evening instruction in her Individualized Education Program (IEP).

Instead, A.J.T. received only 4.25 hours of instruction daily, significantly less than the 6.5-hour school day provided to her nondisabled peers. The district planned to cut her instructional time even further when she entered middle school. Following an administrative complaint, the Minnesota Department of Education determined that the district had violated the Individuals with Disabilities Education Act (IDEA), and federal courts affirmed that ruling.

A.J.T. and her family then pursued additional claims under Section 504 and the ADA, seeking compensatory damages. But both the district court and the Eighth Circuit dismissed those claims, applying the long-standing Monahan v. Nebraska precedent, which required proof that the district acted with “bad faith or gross misjudgment.” Though the Eighth Circuit panel itself questioned the validity of this standard, it felt bound by precedent. The case then went before the U.S. Supreme Court.

The Supreme Court’s Holding: One Standard for All

Chief Justice John Roberts, writing for a unanimous court, rejected the two-tiered system of discrimination standards. The court held that students alleging disability discrimination in education are subject to the same legal standard as plaintiffs in other ADA and Rehabilitation Act cases. There is no textual basis in either statute for requiring students to show bad faith or gross misjudgment — a standard far more demanding than the deliberate indifference standard used elsewhere.

The Court pointed to Congress’s response to the 1984 decision in Smith v. Robinson, in which the Court had previously limited access to broader federal disability rights in the educational context. Congress responded by adding Section 1415(l) to the IDEA, explicitly preserving the rights and remedies available under other federal laws. The Supreme Court cited this provision as a clear signal that the IDEA does not restrict the application of other anti-discrimination statutes.

Implications for K-12 School Districts

The decision in A.J.T. is a watershed moment for school law, and the implications for K-12 districts are significant. These may include:

• Lower legal barriers for plaintiffs: Students no longer need to show that schools acted with bad faith or gross misjudgment to bring successful Section 504 or ADA claims. The more familiar “deliberate indifference” standard will likely govern, requiring only that districts disregarded a known risk of violating a student’s rights.
• Increased risk of damages: Unlike the IDEA, which generally provides only injunctive relief and equitable remedies, Section 504 and the ADA allow for compensatory damages. With the heightened standard removed, students may more readily pursue monetary damages for discrimination, increasing litigation risk and potential financial exposure for districts.
• More Section 504/ADA claims expected: This decision will likely encourage families to bring standalone 504 or ADA claims, rather than or in addition to IDEA claims. These claims are often procedurally simpler and may be more appealing to plaintiffs, especially where monetary relief is sought.

Strategic takeaways

In the post-A.J.T. era, school districts should recognize that IDEA compliance is no longer a shield against liability under Section 504 and the ADA. Legal exposure now extends to how districts respond to disability-related accommodation requests, regardless of IEP sufficiency.

K-12 leaders should consult legal counsel to:

• Reevaluate disability related policies through the lens of equity and risk management.
• Provide staff with updated guidance on handling accommodation requests beyond the IEP process.
• Establish clear protocols for documenting decision-making and demonstrating responsiveness to known student needs.

Districts that take these steps will be better positioned to fulfill their obligations — and avoid costly litigation — in today’s evolving legal landscape.