By Kendall Eaton, Esq.
A.J.T. v. Osseo Area Schools
On January 17, 2025, the Supreme Court of the United States (SCOTUS) agreed to hear the district court case A.J.T. v. Osseo Area Schools out of the 9th Circuit.
Case History
In 2018, Osseo Area Schools, Independent School District No. 279 was limiting a student’s instructional time to less than half the time her peers were receiving due to having epilepsy. Her epilepsy prevented her from attending school before noon. Due to this, her parents requested that her instruction be from noon to 6:00 p.m., like it had been in middle school. However, Osseo Area Schools denied their request. The family filed a complaint with the Minnesota Department of Special Education, claiming that Osseo Area Schools denied their daughter a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA). The administrative law judge (ALJ) and district court judge found that Osseo Area Schools violated the IDEA and awarded her the requested services.
The family also sued Osseo Area Schools under the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act of 1973 (Section 504). The family was asking the court to grant an injunction, which would permanently secure her rights to a full day of school, as well as compensatory damages. The district court ruled against the family stating that the school district’s actions did not meet the 8th Circuit’s standard of bad faith or gross misjudgment. The 9th Circuit pointed to the 1982 decision by the 8th Circuit in Monahan v. Nebraska, which established the bad faith or gross misjudgment standard. The family appealed to SCOTUS, arguing that the 9th Circuit’s strict test should only apply to school settings, not to other ADA and Section 504 plaintiffs.
Issue:
The issue before SCOTUS is whether students filing disability discrimination claims must prove that public school officials acted with discriminatory intent through bad faith or gross misjudgment. This means that the court will be determining the standard for damages in discrimination cases.
Why This Matters:
In an interview with Denise Marshall, the CEO of the Council of Parents, Attorneys, and Advocates (COPAA), she stated that “the current standard under the 9th Circuit is very high, which would make it difficult for students with disabilities to prevail on disability discrimination cases.” If the justices clearly define a uniform standard for damages for disability discrimination claims under the ADA and Section 504 in school settings, it would reduce confusion and increase clarity for the chosen standard across the board.
Moving Forward:
Oral arguments have been set for April 28, 2025. The term for SCOTUS begins on the first Monday in October and goes through the Sunday before the first Monday of the following year. SCOTUS hears oral arguments in cases from October through April. From January through April, arguments are heard during the last two weeks of each month on Mondays, Tuesdays, and Wednesdays.
Definitions:
Free Appropriate Public Education (FAPE): special education and related services which are provided at public expense, under public supervision and direction, and without charge (see 20 U.S.C. §1401(9)).
Individuals with Disabilities Education Act (IDEA): the law that makes a free appropriate public education to eligible children with disabilities throughout the United States and ensures special education and related services to those children.
Administrative Law Judge (ALJ): an independent hearing examiner who presides at an administrative hearing. The ALJ serves as both the judge and the jury in administrative hearings.
Complaint: the first document that is filed by the plaintiff in a case which typically lists all of the facts and reasons why the plaintiff believes he or she is justified in bringing their case.
Injunction: a judicial order that restricts a person from beginning or continuing an action that threatens the legal right of another.
Compensatory damages: the money awarded to a plaintiff to compensate for injury or another loss incurred.
Plaintiff: the party who initiates a lawsuit or a legal action before a court.
