A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279, 605 U.S. 335

A.J.T., a student with severe epilepsy, was denied her parents’ repeated requests for evening instruction as part of her Individualized Education Program (IEP) after moving to Osseo Area Public Schools in Minnesota.
The school district limited A.J.T. to fewer instructional hours compared to non-disabled peers, further reducing them despite evidence that more hours with evening instruction would benefit her.
An Administrative Law Judge and later federal courts found the district had violated the Individuals with Disabilities Education Act (IDEA), ordering compensatory education and evening instruction.
After prevailing under IDEA, A.J.T. and her parents filed suit under the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act, seeking additional remedies including compensatory damages.
The district court and Eighth Circuit ruled against A.J.T., holding school-related ADA and Rehabilitation Act claims require proof of "bad faith or gross misjudgment" by the school—a higher standard than for other disability discrimination contexts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must disabled students prove "bad faith or gross misjudgment" (heightened intent) for ADA/Rehab Act claims about education?	Should not have to meet a higher standard; claims should follow the same standards as other ADA/Rehab Act contexts	Heightened standard is needed to harmonize IDEA with these statutes and prevent overlap; or bad faith/gross misjudgment should apply everywhere	No heightened standard; claims are judged under the same standards as in other disability discrimination cases
Does IDEA limit rights/remedies under the ADA or Rehab Act?	IDEA expressly states it does not limit rights/remedies under other federal statutes	Defended Eighth Circuit rule as harmonizing the statutes	IDEA does not restrict or limit rights/remedies conferred by ADA or Rehab Act
Should showing of "deliberate indifference" suffice for compensatory damages under ADA/Rehab Act?	Yes, argues most circuits find deliberate indifference is enough for damages	Argues for a higher/intent-based standard in all cases	Court left this for future cases, did not decide here
Can the school district raise a broader argument for "bad faith or gross misjudgment" as the standard everywhere?	Not argued below, not in the grant of certiorari, and unfair to change argument now	Tried to introduce at Supreme Court merits stage	Court declined to consider argument not properly presented below

Fry v. Napoleon Community Schools, 580 U.S. 154 (clarified interplay between IDEA and other disability statutes)
United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (syllabus not part of court opinion)
Smith v. Robinson, 468 U.S. 992 (held IDEA was exclusive avenue for challenging special education, later overruled by Congress)
Honig v. Doe, 484 U.S. 305 (explained IDEA hearing procedures)
Alexander v. Sandoval, 532 U.S. 275 (private right of action requires intent for damages under Title VI)
Board of Trustees of Univ. of Ala. v. Garrett, 531 U.S. 356 (constitutional limits on ADA enforcement against states)
Pennhurst State School and Hospital v. Halderman, 451 U.S. 1 (requirements for Spending Clause legislation)
Tennessee v. Lane, 541 U.S. 509 (ADA Title II access to courts for disabled individuals)