A.J.T. v. Osseo Area Schools

A.J.T. (plaintiff) was a teenage girl with a rare and severe type of epilepsy. A.J.T. required assistance with everyday tasks and experienced multiple seizures daily. The frequency of A.J.T.’s morning seizures rendered her unable to attend school before noon, but she was able to learn from noon until 6:00 p.m. Until 2015, A.J.T.’s parents and teachers allowed A.J.T. to avoid morning activities and receive evening instruction at home. However, in 2015, A.J.T.’s family moved to Minnesota, where A.J.T. enrolled in the Osseo Area Public Schools, Independent School District No. 279 (the district) (defendant). The district refused to allow A.J.T. to receive evening instruction, and A.J.T.’s resulting school day was 2.25 hours shorter than that of other students in the district. In 2018, when A.J.T. was entering middle school, the district proposed shortening A.J.T.’s school day even more. A.J.T.’s parents requested that A.J.T. receive evening instruction and a school day of a comparable length to nondisabled students, but administrators denied those requests. A.J.T.’s parents filed a complaint against the district with the Minnesota Department of Education, asserting that the district had violated the Individuals with Disabilities Education Act (IDEA) by failing to provide A.J.T. with a “free appropriate public education.” An administrative-law judge (ALJ) agreed and ordered relief that included allowing A.J.T. to receive at-home instruction from 4:30 to 6:00 p.m. every school day. A federal district court and federal appellate court affirmed the ALJ’s decision. A.J.T. and her parents then sued the district and the school board in federal court, claiming violations of the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The court granted summary judgment for the district, finding that A.J.T. had failed to state a prima facie case of discrimination because she had not shown that the district had acted with bad faith or gross misjudgment, as required by Eighth Circuit precedent. The Eighth Circuit affirmed, and the United States Supreme Court granted certiorari.