Supreme Court Unanimously Rejects Elevated Standard for Disability Discrimination Claims in Education

In a decisive ruling, the U.S. Supreme Court has unanimously rejected a higher standard imposed by lower courts for discrimination claims involving children with disabilities. In the case of A.J.T. v. Osseo Area Schools, Independent School District No. 279, the Court assessed whether students must face a heightened challenge compared to other disabled individuals when contesting discriminatory actions.

The Court’s opinion, authored by Chief Justice John Roberts and supported by all justices, overturned the prevailing approach that students must prove an actual intent to discriminate in order to obtain damages under federal statutes barring disability discrimination, particularly Section 504 of the Rehabilitation Act and Title II of the Americans with Disabilities Act. The ruling emphasized that these laws, along with the Individuals with Disabilities Education Act, do not warrant a stricter standard for educational services.

This decision marks a significant shift from the lower courts’ stance. Historically, these courts have been hesitant to award damages in educational discrimination cases without evidence of deliberate discrimination by school districts. The Supreme Court, however, made it clear that all discrimination claims should be subject to the same standards, highlighting that nothing in the antidiscrimination statutes justifies a more demanding approach specific to educational context.

Chief Justice Roberts pointed out that lower courts have allowed injunctive relief under these statutes without requiring proof of intent. However, for damages, a majority require a demonstration of “deliberate indifference.” The Court did not rule on the correctness of this, but underscored that educational claims should align with other discrimination contexts, bolstered by Congress’ amendment to the statutes disallowing restrictive interpretations.

While the ruling was unanimous, it revealed a divide among the justices regarding unresolved issues. Justices Clarence Thomas and Brett Kavanaugh expressed skepticism about holding school districts liable without intent proof, while Justices Sonia Sotomayor and Ketanji Brown Jackson warned that an intent requirement would transform disability discrimination law, undermining efforts to eliminate barriers.

This decision reinforces the statutory promise of equal treatment, affecting school districts and legal professionals advising on disability law. For further details, the full opinion and analysis can be viewed on SCOTUSblog.