A.J.T. v. Osseo Area Schools

On June 12, 2025, SCOTUS issued a unanimous decision in A.J.T. v. Osseo Area Schools.

Alleging violations of the IDEA, Section 504, and the ADA, AJT and her parents filed for a special education due process hearing against Osseo Area Schools.

They alleged that the shortened school day imposed on AJT was a violation of all three statutes. They sought relief under IDEA and additional relief, to include dollar damages and an injunction, under Section 504 and the ADA.

They alleged that the "special education administrators knew or should have known that shortening a student's school day without a basis in a student's individual needs is substantially likely to result in a violation of federally protected rights."

At the due process hearing, they prevailed on the due process claim, but not on relief under Section 504 and the ADA.

In this Minnesota case, Osseo filed an appeal in the U.S. District Court (Case # 21-1453) on June 21, 2021, but, for reasons unknown, withheld service of process. AJT appealed on August 3, 2021. Their amended complaint was filed on November 8, 2021. (Case # 21-1760)

Later, Osseo filed a Motion to Consolidate and Stay both cases. On February 8, 2022, AJT's counsel, Amy J. Goetz of the School Law Center, filed an impressive brief in opposition, relying extensively on the prior Fry and Perez v. Sturgis decisions issued by SCOTUS in 2017 and 2023.

In the parents' case against Osseo, the District Court dismissed their Section 504 and ADA claims, explaining that -
"In the instant case, Plaintiffs assert three claims against the District:
      (1) violations of the IDEA;
      (2) violations of Section 504 of the Rehabilitation Act of 1973, 29 U.S.C 794 ("Section 504"); and
      (3) violations of the Americans with Disabilities Act ("the ADA")."

"As discussed in detail below, the evidence in the record supports granting Defendants' Motion for Summary Judgment. Even assuming AJT was denied the benefits of a program or activity of a public entity receiving federal funds and/or discriminated against based on her disability, the District did not act with bad faith or gross misjudgment when making educational decisions regarding AJT.

In addition, even if the District took all the actions Plaintiffs allege it took, there is no evidence it did so to retaliate against AJT's parents for their advocacy on behalf of AJT. Finally, Plaintiffs' IDEA claims are foreclosed for a number of reasons. Thus, the District's Motion for Summary Judgment is granted."

But the District Court upheld the IDEA decision from the due process hearing on behalf of AJT, finding that:

"The correct standard is whether AJT's IEP established an educational program that was 'appropriately ambitious in light of her circumstances.' [citing Endrew F. v. Douglas Cnty. Sch. Dist.]"

"Without more than 4.25 hours of schooling a day, the IEP did not establish such a program. AJT's de minimis educational progress since moving to the District does not change that fact, especially in light of her regression in certain areas and the fact that certain historical goals had to be cut from her IEP due to the shortened school day."

"In addition, the District's shifting reasons for denying the in-home instruction AJT seeks to make up for the morning hours she is not in school were never based on AJT's needs. Accordingly, AJT's Motion for Judgment on the Record is granted and the District's Motion is denied."

At the U.S. Court of Appeals for the Eighth Circuit, the parents appealed the District Court dismissal of the Section 504 and ADA claims, and Osseo appealed the adverse IDEA decision. Thus, once again, two separate cases were pending, filed by each party.

The Eighth Circuit ruled in favor of the school district on the Section 504 and ADA claims and in favor of the child and parents on the IDEA case. [Cites: 96 F.4th 1058 (2024) and 96 F.4th 1062 (2024)]

AJT appealed to the U. S. Supreme Court, which reviewed and reversed the Court of Appeals' finding regarding the standard for Section 504 and ADA violations. They explained that A.J.T. is a "qualified individual with a disability" who "was denied the same length school day as her nondisabled peers based on her disability." But that the lower court held that AJT failed to state a prima facie case under Section 504 or the ADA because she did not show that school officials "acted with bad faith or gross misjudgment."

As in Endrew F., this unanimous Opinion was authored by Chief Justice Roberts. SCOTUS explained that children with disabilities and their parents "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."

In other words, the "bad faith or gross misjudgment" standard used in the Eighth Circuit pursuant to the "Monahan" standard in special education cases to find a Section 504 or ADA violation was struck down!

Links below.

June 21, 2021 Complaint filed in Federal Court by Osseo appealing the DP Decision.

November 8, 2021 Amended Complaint filed in Federal Court by AJT appealing the dismissal of Section 504 and ADA claims.

January 3, 2022 Memorandum to Consolidate and Stay filed by Osseo.

February 8, 2022 Memorandum in Opposition to the above filed by AJT.

April 28, 2024 Audio file of the Oral Argument at the U.S. Supreme Court.

April 28, 2024 Transcript of the Oral Argument at the U.S. Supreme Court.

June 12, 2025 SCOTUS Opinion authored by Chief Justice Roberts.

Note: The reference to "lying" and "lied" is on pages 61+62, 79+80 in the transcript. In the audio, you can hear it at 49:30 and again from 1:05 to 1:07:34. The School Board attorney repeatedly interrupted Justice Gorsuch, who took issue with her statements.

Revised: 7/29/2025