AMERICANS WITH DISABILITY ACT – SCHOOL DISTRICT HEIGHTENED STANDARD – REHABILITATION ACT – SCHOOL DISTRICT – HEIGHTENED STANDARD

A.J.T. v. Osseo Area Sch., Indep. Sch. Dist. No. 279, 145 S. Ct. 1647 (June 12, 2025) Roberts, C.J.
CHIEF JUSTICE ROBERTS delivered the opinion of the Court.
Petitioner A. J. T. is a teenage girl who suffers from a rare form of epilepsy that severely limits her physical and cognitive functioning. When school administrators denied her certain educational accommodations, A. J. T.’s parents sued the school district, alleging discrimination on the basis of disability. The courts below held that A. J. T.’s claims could not go forward because she had not shown that school officials acted with “bad faith or gross misjudgment.” That standard, the courts explained, applies uniquely in the educational services context and requires a more demanding showing compared to other sorts of disability discrimination claims. We consider whether the courts below were right to require this heightened showing.
We granted certiorari to resolve the disagreement in the Courts of Appeals over whether schoolchildren bringing ADA and Rehabilitation Act claims relating to their education must make this heightened showing of “bad faith or gross misjudgment.” 604 U. S. ___ (2025).
Outside the context of elementary and secondary education, the Eighth Circuit—in line with the general approach of the courts of appeals—permits plaintiffs to establish a statutory violation and obtain injunctive relief under the ADA and Rehabilitation Act without proving intent to discriminate. See, e.g., Hall v. Higgins, 77 F. 4th 1171, 1180– 1181 (CA8 2023); Midgett v. Tri-Cty. Metropolitan Transp. Dist. of Ore., 254 F. 3d 846, 851 (CA9 2001). To obtain compensatory damages, however, courts of appeals generally agree that a plaintiff must show intentional discrimination. See Hall, 77 F. 4th, at 1181; see also S. H. v. Lower Merion School Dist., 729 F. 3d 248, 262 (CA3 2013) (collecting cases). On that score, “a majority” of the Courts of Appeals to have weighed in on the question—including the Eighth Circuit—find the requirement to show “intentional discrimination” satisfied by proof that the defendant acted with “deliberate indifference.” Id., at 262–263.4 That standard “does not require a showing of personal ill will or animosity toward the disabled person.” Meagley v. Little Rock, 639 F. 3d 384, 389 (CA8 2011). Rather, to show deliberate indifference, it is enough that a plaintiff proves the defendant disregarded a “strong likelihood” that the challenged action would “result in a violation of federally protected rights.” Ibid. We hold today that ADA and Rehabilitation Act claims based on educational services should be subject to the same standards that apply in other disability discrimination contexts. Nothing in the text of Title II of the ADA or Section 504 of the Rehabilitation Act suggests that such claims should be subject to a distinct, more demanding analysis. The substantive provisions of both Title II and Section 504, by their plain terms, apply to “qualified individual[s]” with disabilities. 29 U. S. C. §794(a); 42 U. S. C. §12132. There is no textual indication that the protections of either disability discrimination statute apply with lesser force to certain qualified individuals bringing certain kinds of claims.
That our decision is narrow does not diminish its import for A. J. T. and “a great many children with disabilities and their parents.” Luna Perez v. Sturgis Public Schools, 598 U. S. 142, 146 (2023). Together they face daunting challenges on a daily basis. We hold today that those challenges do not include having to satisfy a more stringent standard of proof than other plaintiffs to establish discrimination under Title II of the ADA and Section 504 of the Rehabilitation Act.
The judgment of the United States Court of Appeals for the Eighth Circuit is vacated, and the case is remanded for further proceedings consistent with this opinion.