96 F.4th 1058
8th Cir.2024Background
- A.J.T., a student with severe morning epilepsy, could not attend school until noon and requested evening instruction to have a full school day.
- Osseo Area Schools repeatedly denied the request for evening instruction.
- A.J.T., through her parents, sued the District for disability discrimination under Section 504 of the Rehabilitation Act and the Americans with Disabilities Act (ADA).
- The district court granted summary judgment for the District, finding no evidence of bad faith or gross misjudgment.
- On appeal, the Eighth Circuit reviewed the summary judgment de novo, analyzing whether the District’s conduct rose to the necessary level of intent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Liability under Section 504/ADA for not providing requested accommodation | District’s denial of evening instruction and failure to follow policies constituted discrimination | District acted reasonably, updated IEP, and provided some accommodations; no bad faith or gross misjudgment | Affirmed summary judgment; no evidence of bad faith/gross misjudgment |
| Sufficiency of District’s actions as "meaningful access" | District’s refusal and inadequate response showed deviation from accepted professional standards | District made efforts: met with parents, updated IEP, provided some at-home instruction | District’s actions could be insufficient, but not so deficient as to prove wrongful intent |
| Procedural compliance with anti-discrimination policies | Failure to report, investigate, or respond to complaints violates standards | Unawareness of complaints by Director does not equal wrongful intent | Non-compliance does not meet high bar for intent |
| Standard for school liability under 504/ADA in education context | Negligence or deliberate indifference is sufficient | Only bad faith or gross misjudgment qualifies | Court applies bad faith/gross misjudgment standard |
Key Cases Cited
- B.M. ex rel. Miller v. S. Callaway R–II Sch. Dist., 732 F.3d 882 (8th Cir. 2013) (sets standard for Section 504/ADA claims in educational services context)
- Monahan v. Nebraska, 687 F.2d 1164 (8th Cir. 1982) (requires proof of bad faith or gross misjudgment for liability)
- Argenyi v. Creighton Univ., 703 F.3d 441 (8th Cir. 2013) (meaningful access under Section 504 requires reasonable accommodations)
- Segal v. Metro. Council, 29 F.4th 399 (8th Cir. 2022) (public entities' obligation for meaningful access under ADA)
- Alexander v. Choate, 469 U.S. 287 (U.S. 1985) (meaningful access and reasonable accommodations required under Section 504)