On June 12, 2025, the United States Supreme Court issued a unanimous decision in A.J.T. v. Osseo Area Schools, affirming that students with disabilities denied a Free Appropriate Public Education (FAPE) under the Individuals with Disabilities Education Act (IDEA) may seek compensatory damages under Section 504 of the Rehabilitation Act and the Americans with Disabilities Act (ADA) without having to prove “bad faith” or “gross misjudgment.” This decision clarifies that deliberate indifference is the appropriate standard in such cases, bringing uniformity and clarity to a previously fragmented legal landscape.
The reporting by K-12 Dive provides an accessible and accurate summary of the decision and the case’s background, which has drawn significant attention from disability advocates, educators, and legal professionals across the country. You can access the full article here: K-12 Dive: Supreme Court raises the bar for school disability liability.
A Case Rooted in Lived Experience
The case of A.J.T. arose from the real-world challenges faced by Ava Tharpe, a Minnesota student with Lennox-Gastaut Syndrome, a form of epilepsy causing frequent and disabling seizures. Her condition made morning instruction virtually impossible. When she attended school in Kentucky, the district accommodated her by adjusting her school hours to 12 p.m. to 6 p.m., in line with her medical needs. After moving to Minnesota in 2015, the Osseo Area Schools district rejected similar accommodations, and Ava received as little as 1.5 hours of instruction per day—far less than her nondisabled peers.
After an administrative law judge determined that the district had violated the IDEA and ordered corrective action, Ava’s parents pursued a civil claim for compensatory damages under Section 504 and the ADA. However, the lower federal courts, following Eighth Circuit precedent, applied a stringent “bad faith or gross misjudgment” standard. As K-12 Dive notes, this approach effectively barred families from obtaining damages in many cases, regardless of how inadequate or inequitable the educational services may have been.
The Supreme Court’s decision overturned that standard. In a clear and unanimous opinion authored by Chief Justice Roberts, the Court concluded that a deliberate indifference standard governs civil damages claims under Section 504 and the ADA—even when those claims arise in the context of education and FAPE violations. The opinion emphasized that students with disabilities should not face a more onerous burden than other plaintiffs under federal civil rights statutes.
A Doctrinal Correction and Legal Clarification
This ruling not only aligns with the general approach to ADA and Section 504 cases outside the education context—it also clarifies a longstanding point of confusion in federal disability law. As discussed in the K-12 Dive article, this case follows the Court’s recent decision in Perez v. Sturgis Public Schools (2023), which held that plaintiffs can pursue ADA damages claims without exhausting the administrative remedies required under IDEA. Together, Perez and A.J.T. strengthen the enforcement mechanisms available to families when schools fail to provide legally mandated services.
By affirming that deliberate indifference—not bad faith—is the proper standard, the Court has given families a more realistic chance of holding districts accountable when harm occurs. The decision will also have a harmonizing effect: as noted in the article, different circuits had applied inconsistent standards, leading to a patchwork of protections that varied dramatically by jurisdiction. Now, all courts are bound by the same threshold, ensuring consistency in how civil rights laws are applied to students with disabilities.
Impact on School Districts and Legal Compliance
This ruling sends a clear message to school districts: when students with disabilities are known to be underserved or denied necessary accommodations, inaction can be grounds for liability—even in the absence of ill will. The K-12 Dive article underscores this point by highlighting the operational consequences of the decision. It compels school districts to revisit how they assess requests for accommodations, how they document their decision-making, and how they ensure fidelity to individualized education plans.
Districts that previously relied on procedural defenses or narrow interpretations of FAPE obligations will now face increased scrutiny. This is particularly true in cases where families have already prevailed under IDEA and seek further remedies under civil rights statutes. The A.J.T. decision effectively closes a loophole that allowed districts to avoid financial accountability even after an administrative finding of educational harm.
At Ratlif Jackson LLP, we expect that compliance officers, special education administrators, and legal counsel across the country will need to adapt internal processes and professional development protocols to align with this new standard. It is no longer sufficient to argue that a denial of service was not “grossly misjudged”—what matters is whether the school was aware of a student’s needs and failed to respond appropriately.
What This Means for Families
For families, this decision is monumental. It affirms that civil rights laws have real teeth in the educational context. It confirms that remedies are not limited to prospective relief or minor procedural fixes. And it signals to schools that families have a right to pursue financial compensation when their child suffers educational deprivation due to inaction or systemic failure.
While the K-12 Dive article focuses primarily on the legal ramifications, the human dimension is equally important. This case is about a child—Ava Tharpe—whose access to learning was severely curtailed despite clear medical documentation and a known history of effective accommodations. The failure to replicate those supports was not merely an oversight; it was an institutional decision that had tangible consequences. Now, thanks to the Supreme Court’s ruling, families in similar situations will have a clearer path to justice.
The article also highlights how this decision reaffirms the essential balance between IDEA’s procedural safeguards and the broader substantive protections offered by the ADA and Section 504. These statutes serve distinct but complementary roles. While IDEA focuses on the delivery of educational services through individualized plans, Section 504 and the ADA ensure that students are not subject to discrimination, exclusion, or unequal treatment.
A Nationwide Shift in Legal Culture
This ruling will likely prompt a shift in how schools approach disability-related decisions. We may see increased caution in denying accommodation requests, more thorough documentation of student needs, and a greater willingness to engage in creative solutions when conventional scheduling or classroom structures fail to meet a child’s needs.
Importantly, this decision also reinforces a legal culture in which equity is prioritized over institutional convenience. Schools that attempt to “ride out” disputes or delay action may now face legal exposure not just at the administrative level, but in federal court. The clarity brought by the Court’s opinion also gives parents, advocates, and attorneys stronger tools to negotiate early and more effectively.
At Ratlif Jackson LLP, we believe this decision will ultimately lead to stronger school-parent collaboration, earlier dispute resolution, and better educational outcomes—if districts rise to meet the new legal standard with good faith and transparency.
Final Reflections
The Supreme Court’s ruling in A.J.T. v. Osseo Area Schools will resonate for years to come. It ensures that when schools fail to act in the face of known disability-related needs, families have a meaningful avenue for recourse. As the K-12 Dive article thoughtfully details, the ruling not only corrects a doctrinal misalignment—it restores fairness to the system by ensuring that students with disabilities are not held to a higher evidentiary burden than any other group of civil rights plaintiffs.
For families navigating the complexities of educational accommodations and potential discrimination, understanding your rights under the ADA and Section 504 is crucial. If you believe your child’s educational needs are not being adequately met, consider contacting our team. Our education law attorneys are experienced in advocating for students with disabilities and can help you explore all available legal remedies, including pursuing claims under IDEA, Section 504, and the ADA. We are committed to ensuring every child receives the support and equality they deserve in school settings.