Student needn’t show ‘bad faith’ in suing for accommodation, SCOTUS rules

In suing for relief under the Americans with Disabilities Act and Rehabilitation Act, a Minnesota public school student who suffers from a rare form of epilepsy that impairs her ability to learn during morning hours was not required to show school officials acted with “bad faith or gross misjudgment” in denying her accommodations, a unanimous U.S. Supreme Court has ruled in reversing a decision from the 8th Circuit.

BULLET POINTS: “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. 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.”

— Chief Justice John G. Roberts, opinion of the court

“At the merits stage, the [Osseo School] District asked us to go beyond the question presented. Specifically, it urged us to clarify the particular standards that should apply in Title II and Section 504 litigation. In most courts of appeals, the operative standard for discrimination claims under these statutes turns on the kind of relief sought. To establish a violation or to obtain injunctive relief, the plaintiff need not prove intentional discrimination. But, to obtain compensatory damages, courts generally agree that a plaintiff must prove that the defendant was at least ‘deliberately indifferent’ to federally protected rights. The District challenges the no-intent standard, arguing that intent to discriminate should be required to establish a violation or to obtain any kind of relief. It presses its theory on both statutory and constitutional grounds.…

“I express no definitive views on the additional issues raised by the District here. And, I agree with the Court’s decision to answer only the question presented today. But, in a case where the District’s additional issues are properly before us, I would be willing to address them. Whether federal courts are applying the correct legal standard under two widely utilized federal statutes is an issue of national importance, and the District has raised serious arguments that the prevailing standards are incorrect.”

— Justice Clarence Thomas, concurring

“I join in full the Court’s opinion, which holds that ADA and Rehabilitation Act claims regarding educational services are subject to the same standards applied in other disability discrimination contexts. In reaching that conclusion, the Court rightly declines to entertain respondents’ newly raised argument that ‘bad faith or gross misjudgment’ is the correct standard for all disability discrimination claims under Title II and Section 504 of those Acts. I write separately, however, to highlight a foundational flaw in respondents’ theory. Respondents contend that the ‘bad faith or gross misjudgment’ standard is appropriate because the statutes require a showing of ‘improper purpose’ or ‘animus.’ That is incorrect. The statutes’ text and history, as well as this Court’s precedent, foreclose any such purpose requirement.”

— Justice Sonia Sotomayor, joined by Justice Ketanji Brown Jackson, concurring