A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279

Summary

Schoolchildren bringing claims related to their education under either Title II of the Americans with Disabilities Act or Section 504 of the Rehabilitation Act are not required to make a heightened showing of “bad faith or gross misjudgment” but instead are subject to the same standards that apply in other disability discrimination contexts.

Text

PRELIMINARY PRINT 
Volume 605 U. S. Part 2 
Pages 335–359 
OFFICIAL REPORTS 
OF 
THE SUPREME COURT 
June 12, 2025 
REBECCA A. WOMELDORF 
reporter of decisions 
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OCTOBER TERM, 2024 335 
Syllabus 
A. J. T., by and through her parents, A. T., et al. v. 
OSSEO AREA SCHOOLS, INDEPENDENT SCHOOL 
DISTRICT NO. 279, et al. 
certiorari to the united states court of appeals for 
the eighth circuit 
No. 24–249. Argued April 28, 2025—Decided June 12, 2025 
Multiple federal laws afford protections for children with disabilities in 
public schools. Three statutory schemes are particularly relevant to 
this case. Section 504 of the Rehabilitation Act of 1973 provides that 
no qualifed individual with a disability shall be excluded from participa-
tion in, denied the benefts of, or subjected to discrimination under any 
federally funded program solely by reason of her or his disability. Simi-
larly, Title II of the Americans with Disabilities Act (ADA) prohibits 
qualifed individuals with disabilities from being excluded from or de-
nied the benefts of a public entity's services, programs, or activities by 
reason of disability. While the antidiscrimination guarantees of Section 
504 and Title II apply in a variety of contexts, the Individuals with 
Disabilities Education Act (IDEA) offers federal funds to States in ex-
change for the commitment to furnish the core guarantee of a “free 
appropriate public education” to children in public schools with certain 
physical or intellectual disabilities. The centerpiece of the IDEA is 
the provision of an “individualized educational program,” (IEP) which 
“spells out” a plan to meet all of the educational needs of a child with a 
qualifying disability. Fry v. Napoleon Community Schools, 580 U. S. 
154, 158. 
Petitioner A. J. T. is a teenage girl with a rare form of epilepsy that 
severely limits her physical and cognitive functioning. She suffers from 
seizures that are so frequent in the mornings that she cannot attend 
school before noon, though she is alert and able to learn from noon until 
6 p.m. For the frst few years of her schooling, school offcials accommo-
dated A. J. T.'s condition by permitting her to avoid morning activities 
and instead receive evening instruction. But when A. J. T.'s family 
moved to Minnesota in 2015, her new school district—Osseo Area Public 
Schools, Independent District No. 279—denied her parents' repeated 
requests to include evening instruction in A. J. T.'s IEP. Between 2015 
and 2018, A. J. T. received only 4.25 hours of instruction daily compared 
to the typical 6.5-hour school day for nondisabled students in the dis-
trict. After even further cuts to A. J. T.'s school day were proposed, 
her parents fled an IDEA complaint with the Minnesota Department

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336 A. J. T. v. OSSEO AREA SCHOOLS, INDEPENDENT 
SCHOOL DIST. NO. 279 
Syllabus 
of Education, alleging that the school's refusal to provide afterhours 
instruction denied A. J. T. a free appropriate public education. An Ad-
ministrative Law Judge determined that the school district had vio-
lated the IDEA and ordered the school to provide compensatory educa-
tion and evening instruction. Federal courts subsequently affrmed 
A. J. T.'s IDEA victory. 
A. J. T. and her parents then sued under the ADA and the Rehabilita-
tion Act, requesting a permanent injunction, reimbursement for certain 
costs, and compensatory damages. The District Court granted sum-
mary judgment for the school, and the Eighth Circuit affrmed. In so 
holding, the Eighth Circuit stated that a school district's failure to pro-
vide a reasonable accommodation was not enough to state a prima facie 
case of discrimination under Monahan v. Nebraska, 687 F. 2d 1164, 
which requires a plaintiff to prove conduct by school offcials rising to 
the level of bad faith or gross misjudgment. 
Held: Schoolchildren bringing ADA and Rehabilitation Act claims related 
to their education are not required to make a heightened showing of 
“bad faith or gross misjudgment” but instead are subject to the same 
standards that apply in other disability discrimination contexts. 
Pp. 344–351. 
(a) Outside the educational services context, courts of appeals permit 
plaintiffs to establish violations and obtain injunctive relief under the 
ADA and Rehabilitation Act without proving intent to discriminate. 
To obtain compensatory damages, courts generally require a showing of 
intentional discrimination, which most circuits fnd satisfed by “deliber-
ate indifference”—a standard requiring only a showing that the defend-
ant disregarded a strong likelihood that the challenged action would 
violate federally protected rights. Nothing in the text of the applicable 
substantive protections or remedial provisions of Title II of the ADA 
or Section 504 of the Rehabilitation Act suggests that claims based on 
educational services should be subject to a distinct, more demanding 
analysis. Pp. 344–345. 
(b) Some courts, however, have come to apply a heightened intent 
standard to ADA and Rehabilitation Act claims in the educational serv-
ices context. This standard traces back to the “bad faith or gross mis-
judgment” rule articulated by the Eighth Circuit in its 1982 decision in 
Monahan, in which the Eighth Circuit reasoned that to prove discrimi-
nation under the Rehabilitation Act in the educational context, a plain-
tiff must show “something more than a mere failure to provide” a free 
appropriate public education. 687 F. 2d, at 1170. The court explained 
a heightened showing of bad faith or gross misjudgment was necessary

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to “harmonize” the Rehabilitation Act and the IDEA and to refect the 
proper balance between disabled children's rights, state offcials' respon-
sibilities, and courts' competence in technical felds. Id., at 1171. 
In Smith v. Robinson, 468 U. S. 992, this Court similarly tried to “har-
monize” the IDEA's specifc guarantee of a free appropriate public edu-
cation with the protections of other antidiscrimination laws, ultimately 
concluding that the IDEA's comprehensive statutory scheme was the 
exclusive avenue by which a disabled child or his parents could chal-
lenge the adequacy of his education. Within two years, however, Con-
gress enacted a new provision of the IDEA overturning Smith. That 
provision, now codifed at 20 U. S. C. § 1415( l), provides that nothing in 
the IDEA “shall be construed to restrict or limit the rights, procedures, 
and remedies available under” the ADA, Rehabilitation Act, or other 
federal laws protecting disabled children's rights. This provision 
makes clear that the IDEA does not restrict or limit rights or remedies 
that other federal antidiscrimination statutes independently confer on 
children with disabilities. The bad faith or gross misjudgment rule de-
rived from Monahan is irreconcilable with the unambiguous directive 
of § 1415(l). In imposing a higher bar for discrimination claims based 
on educational services as compared to other sorts of disability discrimi-
nation claims, the Eighth Circuit effectively read the IDEA to implicitly 
limit the ability of disabled schoolchildren to vindicate their independent 
ADA and Rehabilitation Act rights, thereby making it more diffcult to 
secure the statutory remedies provided by Congress. Pp. 345–349. 
(c) The school district no longer defends Monahan's asymmetric rule, 
and contends instead that bad faith or gross misjudgment is the correct 
standard of intent for all ADA and Rehabilitation Act claims, whether 
in or out of schools. This argument was not resolved below, was not 
raised in the brief in opposition to certiorari, and is outside the question 
presented. The Court declines the invitation to inject into this case 
signifcant issues that have not been fully presented. Pp. 349–351. 
96 F. 4th 1058, vacated and remanded. 
Roberts, C. J., delivered the opinion for a unanimous Court. Thomas, 
J., fled a concurring opinion, in which Kavanaugh, J., joined, post, 
p. 351. Sotomayor, J., fled a concurring opinion, in which Jackson, J., 
joined, post, p. 355. 
Roman Martinez argued the cause for petitioner. With 
him on the briefs were Peter A. Prindiville , Nicholas Rosel-
lini, and Amy J. Goetz.

338 A. J. T. v. OSSEO AREA SCHOOLS, INDEPENDENT 
SCHOOL DIST. NO. 279 
Opinion of the Court 
Nicole Frazer Reaves argued the cause for the United 
States as amicus curiae urging vacatur . With her on the 
brief were Deputy Solicitor General Gannon, Acting Assist-
ant Attorney General Roth, Deputy Assistant Attorney 
General Warner, Deputy Solicitor General Stewart, Sydney 
A. R. Foster, Ellen Noble, Charles W. Scarborough, Cather-
ine Padhi, and Thomas Wheeler . 
Lisa S. Blatt argued the cause for respondents. With 
her on the brief were Charles L. McCloud, Aaron Z. Roper, 
Laura Tubbs Booth, Christian R. Shafer , and Adam J . 
Frudden.* 
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 
offcials acted with “bad faith or gross misjudgment.” That 
standard, the courts explained, applies uniquely in the educa-
tional services context and requires a more demanding show-
*Briefs of amici curiae urging reversal were fled for the Council of 
Parent Attorneys and Advocates et al. by Brian Wolfman, Regina Wang, 
and Selene A. Almazan-Altobelli; and for Rep. Tony Coelho et al. by 
David A. Strauss, Sarah M. Konsky, and Matthew S. Hellman. 
A brief of amici curiae urging affrmance was fled for the State of 
Tennessee et al. by Jonathan Skrmetti, Attorney General of Tennessee, J. 
Matthew Rice , Solicitor General, Whitney D. Hermandorfer , and Virginia 
N. Adamson, Assistant Solicitor General, and by the Attorneys General 
for their respective States as follows: Tim Griffn of Arkansas, James 
Uthmeier of Florida, Raúl Labrador of Idaho, Aaron M. Frey of Maine, 
Lynn Fitch of Mississippi, and Ken Paxton of Texas. 
Sonja H. Trainor and W. Stuart Stuller fled a brief for AASA, The 
School Superintendents Association et al. as amici curiae . 
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ing compared to other sorts of disability discrimination 
claims. We consider whether the courts below were right 
to require this heightened showing. 
I 
A 
Multiple federal laws afford “diverse” (and occasionally 
overlapping) protections for children with disabilities in pub-
lic schools. Fry v. Napoleon Community Schools, 580 U. S. 
154, 170 (2017); see id., at 170–171. Three are particularly 
relevant to this case. Beginning with two broadly applica-
ble such laws, both Section 504 of the Rehabilitation Act of 
1973, 87 Stat. 394, as amended, 29 U. S. C. § 794, and Title II 
of the Americans with Disabilities Act of 1990 (ADA), 104 
Stat. 337, as amended, 42 U. S. C. § 12131 et seq ., prohibit 
discrimination on the basis of disability in a wide variety 
of contexts. See Fry, 580 U. S., at 159. Section 504 of the 
Rehabilitation Act provides: “No otherwise qualifed individ-
ual with a disability . . . shall, solely by reason of her or his 
disability, be excluded from the participation in, be denied 
the benefts of, or be subjected to discrimination under any 
program or activity receiving Federal fnancial assistance.” 
29 U. S. C. § 794(a). Similarly, under Title II of the ADA, 
“no qualifed individual with a disability shall, by reason of 
such disability, be excluded from participation in or be denied 
the benefts of the services, programs, or activities of a public 
entity, or be subjected to discrimination by any such entity.” 
42 U. S. C. § 12132. Both Section 504 and Title II “authorize 
individuals to seek redress for violations of their substantive 
guarantees by bringing suits for injunctive relief or money 
damages.” Fry, 580 U. S., at 160; see 29 U. S. C. § 794a(a)(2); 
42 U. S. C. § 12133. 
Beyond these generally applicable antidiscrimination laws, 
the Individuals with Disabilities Education Act (IDEA), 84 
Stat. 175, as amended, 20 U. S. C. § 1400 et seq., “offers fed-
eral funds to States in exchange for a commitment: to fur-
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340 A. J. T. v. OSSEO AREA SCHOOLS, INDEPENDENT 
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Opinion of the Court 
nish” the core guarantee of a “ `free appropriate public educa-
tion' . . . to all children with certain physical or intellectual 
disabilities.” Fry, 580 U. S., at 158 (quoting § 1412(a)(1)(A)).1 
To that end, once a State accepts the IDEA's fnancial assist-
ance, it must provide “ `special education and related serv-
ices,' ” including “ `instruction' tailored to meet a child's 
`unique needs' and suffcient `supportive services' to permit 
the child to beneft from that instruction.” Id., at 158 (quot-
ing §§ 1401(9), (26), (29)). 
The IDEA's “primary vehicle for implementing these con-
gressional goals is the `individualized educational program' 
(IEP).” Honig v. Doe, 484 U. S. 305, 311 (1988). An IEP 
“spells out” for each child with a qualifying disability “a per-
sonalized plan to meet all of the child's `educational needs.' ” 
Fry, 580 U. S., at 158 (quoting § 1414(d)(1)(A)(i)(II)(bb)). It 
is developed through a collaborative process between a 
child's parents, teachers, and school offcials. See id., at 158. 
But since “parents and school representatives sometimes 
cannot agree” on all aspects of an IEP, “the IDEA estab-
lishes formal procedures for resolving disputes,” starting 
with administrative review in a local or state educational 
agency, followed by the availability of judicial review in state 
or federal court. Id., at 159. 
B 
Petitioner A. J. T. “requires assistance with everyday tasks 
like walking and toileting,” and suffers from seizures 
throughout the day that create safety concerns and interfere 
with her capacity to learn. 96 F. 4th 1062, 1064 (CA8 2024); 
see App. 515. Although A. J. T.'s seizures are so frequent 
in the morning that she “can't attend school before noon,” 
1 The IDEA was previously called “the Education of the Handicapped 
Act.” Fry v. Napoleon Community Schools, 580 U. S. 154, 160, n. 1 
(2017). Congress renamed the law in 1990. See ibid. We refer to the 
statute and its predecessor versions as the IDEA throughout this opinion. 
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she is “alert and able to learn” from noon until about 6 p.m. 
96 F. 4th, at 1064. 2 
For the frst few years of her schooling, A. J. T.'s parents 
and educators accommodated her condition by permitting 
her to avoid activities before midday and to receive evening 
instruction at home. See ibid. That changed in 2015 when 
A. J. T., then ten years old, moved with her family to Minne-
sota. A. J. T.'s new school district, Osseo Area Public 
Schools, Independent School District No. 279, denied her par-
ents' repeated requests to include evening instruction in her 
IEP. See ibid. As a result, between 2015 and 2018, A. J. T. 
received 4.25 hours of instruction each day, as compared to 
the typical 6.5 hour school day for other students. Ibid.; No. 
21–cv–1760 (D Minn., Feb. 1, 2023), App. to Pet. for Cert. 8a. 
In 2018, as the district prepared for A. J. T. to enter middle 
school, it proposed further cutting back the length of her 
school day. 96 F. 4th, at 1064. A. J. T.'s parents again 
requested that she receive evening instruction and school-
ing hours comparable to her nondisabled peers. See ibid. 
School administrators again denied those requests, and also 
rejected proposals to maintain at least the same length in-
structional day that A. J. T. had been receiving in elementary 
school. Ibid. 
“Realizing that an agreement was beyond reach,” A. J. T.'s 
parents fled an IDEA complaint with the Minnesota Depart-
ment of Education, alleging that the school's refusal to pro-
vide afterhours instruction denied A. J. T. a free appropriate 
public education. See id., at 1064–1065. After a fve day 
evidentiary hearing, an Administrative Law Judge deter-
mined that the district had violated the IDEA. Id., at 1065. 
The judge ordered the school to provide several hundred 
2 Because this case comes to us on review of respondents' motion for 
summary judgment, we view the evidence in the light most favorable to 
A. J. T. Tolan v. Cotton, 572 U. S. 650, 657 (2014) (per curiam ). 
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hours of compensatory education and “add certain services 
to [A. J. T.'s] IEP, including at-home instruction from 4:30 
p.m. to 6:00 p.m. each school day.” Ibid. 
The school district sought judicial review, and a Federal 
District Court affrmed. 2022 WL 4226097, *21 (Minn., 
Sept. 13, 2022). The court agreed with the agency that 
school offcials' “steadfas[t] refus[al]” to provide A. J. T. eve-
ning instruction, and “shifting reasons” for doing so, were 
based not on A. J. T.'s needs but on concerns of “[a]dministra-
tive convenience”—namely, maintaining “the regular hours 
of the faculty.” Id., at *1, *13. The Eighth Circuit subse-
quently affrmed A. J. T.'s IDEA victory, agreeing with the 
District Court that the evidence showed that the school dis-
trict's “choice to prioritize its administrative concerns had a 
negative impact on A. J. T.'s learning” and that she “would 
have made more progress with evening instruction.” 96 F. 
4th, at 1067. 
C 
A. J. T. and her parents then sued the school district and 
the Osseo School Board (collectively, the District) in federal 
court, alleging violations of Title II of the ADA and Section 
504 of the Rehabilitation Act. See App. 28–29. They re-
quested a permanent injunction, reimbursement for certain 
costs, and compensatory damages. Ibid. 
The trial court granted the District's motion for summary 
judgment. It acknowledged that A. J. T. is a “qualifed indi-
vidual with a disability” who “was denied the same length 
school day as her nondisabled peers based on her disability.” 
App. to Pet. for Cert. 20a. But the court held that A. J. T. 
failed to state a prima facie case under Section 504 or the 
ADA because she did not show that school offcials “acted 
with bad faith or gross misjudgment.” Id., at 35a–36a. 
The Eighth Circuit affrmed. 96 F. 4th 1058, 1060 (2024). 
It explained that, under Circuit precedent, when “alleged 
ADA and Section 504 violations are `based on educational 
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services for disabled children,' a school district's simple fail-
ure to provide a reasonable accommodation is not enough to 
trigger liability.” Id., at 1061 (quoting B. M. v. S. Callaway 
R–II School Dist., 732 F. 3d 882, 887 (CA8 2013)). Rather, 
“a plaintiff must prove that school offcials acted with `either 
bad faith or gross misjudgment,' which requires ` “something 
more” than mere non-compliance with the applicable federal 
statutes.' ” 96 F. 4th, at 1061 (frst quoting Monahan v. Ne-
braska, 687 F. 2d 1164, 1171 (CA8 1982); then quoting B. M., 
732 F. 3d, at 887; citation omitted). The panel explained 
that, while “A. J. T. may have established a genuine dispute 
about whether the district was negligent or even deliber-
ately indifferent,” under the Eighth Circuit's controlling 
standard, “that's just not enough.” 96 F. 4th, at 1061. 
Since A. J. T. “failed to identify conduct” rising to the level 
of bad faith or gross misjudgment, the court said it was “con-
strained to hold that summary judgment was proper.” Ibid. 
The panel itself, however, went on to question why the 
Eighth Circuit imposes “such a high bar for claims based on 
educational services,” when it “require[s] much less in other 
disability-discrimination contexts.” Ibid., n. 2 (citing cases 
requiring “no intent” for a “failure-to-accommodate claim” 
and “deliberate indifference” for damages). “The answer,” 
the panel said, “is a lesson in why `[w]e do not . . . add provi-
sions to . . . federal statute[s].' ” Ibid. (quoting Alabama 
v. North Carolina, 560 U. S. 330, 352 (2010); alterations in 
original). The Circuit's “bad faith or gross misjudgment 
rule,” the panel opined, added “without any anchor in statu-
tory text . . . a judicial gloss on Section 504,” based on “spec-
ulat[ion] that Congress intended the IDEA's predecessor to 
limit Section 504's protections.” 96 F. 4th, at 1062, n. 2 (cit-
ing Monahan, 687 F. 2d, at 1170–1171). The panel observed 
that this rule had “spread like wildfre” in the lower courts, 
although it “ha[d] been questioned” along the way. 96 F. 
4th, at 1062, n. 2. And since the rule “remain[ed] the law”

344 A. J. T. v. OSSEO AREA SCHOOLS, INDEPENDENT 
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Opinion of the Court 
in the Eighth Circuit, the panel was bound to follow it. Ibid. 
A. J. T.'s petition for rehearing en banc was denied, with 
three judges dissenting. App. to Pet. for Cert. 44a–45a. 
We granted certiorari to resolve the disagreement in the 
Courts of Appeals over whether schoolchildren bringing 
ADA and Rehabilitation Act claims relating to their educa-
tion must make this heightened showing of “bad faith or 
gross misjudgment.” 604 U. S. 1096 (2025).
3 
II 
A 
Outside the context of elementary and secondary educa-
tion, 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 dis-
criminate. See, e. g., Hall v. Higgins, 77 F. 4th 1171, 1180– 
1181 (CA8 2023); Midgett v. Tri-County Metropolitan Transp. 
Dist. of Ore., 254 F. 3d 846, 851 (CA9 2001). To obtain com-
pensatory 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— 
fnd the requirement to show “intentional discrimination” 
satisfed by proof that the defendant acted with “deliberate 
indifference.” Id., at 262–263.
4 That standard “does not 
3 Compare I. Z. M. v. Rosemount–Apple Valley–Eagan Public Schools, 
863 F. 3d 966, 973, n. 6 (CA8 2017) (collecting cases applying this stand-
ard to “alleged discrimination regard[ing] the education of disabled stud-
ents”), with, e. g., D. E. v. Central Dauphin School Dist., 765 F. 3d 260, 
269 (CA3 2014) (applying deliberate indifference standard for compensatory 
damages). 
4 Lower courts appear to have derived this standard from our caselaw 
applying Title IX (which, like the Rehabilitation Act and ADA, was “mod-
eled after Title VI”). Gebser v. Lago Vista Independent School Dist., 524 
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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 prove 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 con-
texts. 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 “qualifed 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 disabil-
ity discrimination statute apply with lesser force to certain 
qualifed individuals bringing certain kinds of claims. 
Nor do the applicable remedial provisions suggest any 
such distinction. Both Title II and Section 504 make the 
“remedies, procedures, and rights” provided therein avail-
able to “any person.” 29 U. S. C. § 794a(a)(2) (“any person 
aggrieved”); 42 U. S. C. § 12133 (“any person alleging dis-
crimination”). That language is expansive and unqualifed, 
confrming applicability to every such person, “without dis-
tinction or limitation.” SAS Institute Inc. v. Iancu, 584 
U. S. 357, 363 (2018) (quoting Oxford English Dictionary (3d 
ed., Mar. 2016)). 
How, then, did some courts of appeals come to apply a 
heightened intent standard to ADA and Rehabilitation Act 
claims concerning educational opportunities? The bad faith 
or gross misjudgment rule traces to the Eighth Circuit's 
opinion in Monahan v. Nebraska, 687 F. 2d 1164. See 96 F. 
4th, at 1061, n. 2. There the Eighth Circuit—in a case in-
U. S. 274, 286, 290 (1998); see also Brief for United States as Amicus Cu-
riae 15–20. 
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volving an IDEA claim and a Rehabilitation Act claim alleg-
ing “improper educational placement”—explained its view 
that “in order to show a violation of the Rehabilitation Act, 
something more than a mere failure to provide” the free ap-
propriate public education “required by [the IDEA] must be 
shown.” Monahan, 687 F. 2d, at 1169–1170. That “some-
thing more,” the Eighth Circuit said, is “bad faith or gross 
misjudgment,” which in its view “should be shown before a 
§ 504 violation can be made out, at least in the context of 
education of handicapped children.” Id., at 1170–1171.
5 
The Eighth Circuit explained that the bad faith or gross 
misjudgment “standard of liability” was consistent with its 
“duty to harmonize the Rehabilitation Act and the [IDEA] 
to the fullest extent possible, and to give each of these stat-
utes the full play intended by Congress.” Id., at 1171. The 
court also concluded that this standard “refect[ed] . . . a 
proper balance between the rights of handicapped children, 
the responsibilities of state educational offcials, and the com-
petence of courts to make judgments in technical felds.” 
Ibid. (“So long as the state offcials involved [did not] depart 
grossly from accepted standards among educational profes-
sionals, we cannot believe that Congress intended to create 
liability under § 504.”). 
B 
The Monahan court was not alone in its instinct to try to 
“harmonize” the IDEA's specifc guarantee of a free appro-
priate public education, on the one hand, with more broadly 
applicable antidiscrimination laws, on the other. Indeed, 
just two years later in Smith v. Robinson, 468 U. S. 992 
(1984), this Court applied virtually identical reasoning to 
hold that the IDEA was “ `the exclusive avenue' through 
which a child with a disability (or his parents) could chal-
5 The Eighth Circuit subsequently extended this standard to education 
related claims brought under the ADA. See Hoekstra v. Independent 
School Dist. No. 283, 103 F. 3d 624, 626–627 (1996). 
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lenge the adequacy of his education.” Fry, 580 U. S., at 160 
(quoting Smith, 468 U. S., at 1009). 
The plaintiffs in Smith sued a school district under the 
IDEA “to secure a `free appropriate public education' ” for 
their handicapped child, id., at 994, and “appended” to their 
complaint “virtually identical claims . . . under § 504 of the 
Rehabilitation Act,” Fry, 580 U. S., at 160 (internal quotation 
marks omitted). In “consider[ing] the interaction between” 
the two statutes, ibid., the Smith Court looked to “the com-
prehensive nature of the procedures and guarantees” set out 
in the IDEA, which the Court thought evinced “Congress' 
express efforts to place on local and state educational agen-
cies the primary responsibility for developing a plan to ac-
commodate the needs of each individual handicapped child,” 
468 U. S., at 1011; see id., at 1016. In light of this “compre-
hensive scheme,” this Court found it “diffcult to believe that 
Congress also meant to leave undisturbed the ability of a 
handicapped child to go directly to court” with a Rehabilita-
tion Act claim. Id., at 1009, 1011, 1016. Such a result, the 
Court said, would effectively permit a plaintiff “to circum-
vent” and “render superfuous most of the detailed proce-
dural protections outlined” in the IDEA. Id., at 1011–1012. 
And “more important, it would also run counter to Congress' 
view that the needs of handicapped children are best accom-
modated” through the IDEA's “carefully tailored scheme.” 
Id., at 1012. 
Congress apparently did not agree. Within two years, it 
enacted a new provision of the IDEA, “overturn[ing]” Smith 
and “ `reaffrm[ing] the viability' of federal statutes like the 
ADA or Rehabilitation Act `as separate vehicles,' no less in-
tegral than the IDEA, `for ensuring the rights of handi-
capped children.' ” Fry, 580 U. S., at 161 (quoting H. R. Rep. 
No. 99–296, pp. 4, 6 (1985)). Now codifed at 20 U. S. C. 
§ 1415(l), that provision states in relevant part: 
“Nothing in [the IDEA] shall be construed to restrict 
or limit the rights, procedures, and remedies available 
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348 A. J. T. v. OSSEO AREA SCHOOLS, INDEPENDENT 
SCHOOL DIST. NO. 279 
Opinion of the Court 
under the Constitution, the [ADA], title V of the Reha-
bilitation Act [including § 504], or other Federal laws 
protecting the rights of children with disabilities, except 
that before the fling of a civil action under such laws 
seeking relief that is also available under [the IDEA], 
the [IDEA's administrative procedures shall frst be 
exhausted].” 
The plain text of § 1415( l) accordingly “makes clear that 
nothing in the IDEA `restrict[s] or limit[s] the rights [or] 
remedies' that other federal laws, including antidiscrimina-
tion statutes, confer on children with disabilities.” Fry, 580 
U. S., at 157 (quoting 20 U. S. C. § 1415(l)). And that explicit 
edict applies “even” to a plaintiff who—“as in Smith itself”— 
seeks relief “that is also available under” the IDEA. Fry, 
580 U. S., at 161. 
In imposing a higher “bar for claims based on educational 
services” as compared to “other disability-discrimination 
contexts,” however, the Eighth Circuit in Monahan effec-
tively read the IDEA to implicitly limit the ability of chil-
dren with disabilities to vindicate their independent ADA 
and Rehabilitation Act rights. 96 F. 4th, at 1061–1062, n. 2 
(recognizing that Congress “rejected Monahan's premise” in 
enacting § 1415(l)). And the court thereby made it more dif-
fcult for disabled schoolchildren to secure the statutory rem-
edies provided by Congress in Title II and Section 504. 
That approach is irreconcilable with the unambiguous direc-
tive of § 1415(l).
6 
The District maintains that Monahan's rule survives 
§ 1415(l). That is so, it says, because the Eighth Circuit de-
rived the bad faith or gross misjudgment standard based 
solely on Section 504's text, rather than anything to do with 
6 Because we address only the application of the heightened bad faith 
or gross misjudgment standard of intent to education related ADA and 
Rehabilitation Act claims, our opinion should not be read to speak to any 
other showing that a plaintiff must make in order to prove a violation of 
the respective requirements of those statutes or the IDEA. 
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Cite as: 605 U. S. 335 (2025) 349 
Opinion of the Court 
the IDEA. Brief for Respondents 24–25. The District in-
sists that the court's statements that its chosen standard 
best harmonized and gave full play to the two statutes, while 
also balancing the interests of disabled schoolchildren and 
state educational offcials, were mere observations of “the 
salutary policy benefts” of an analysis otherwise driven by 
the text of Section 504. Id., at 25. And the court's re-
peated references to education of “handicapped children,” it 
says, were simply descriptions of the “fact pattern at 
hand”—not suggestions that the bad faith or gross misjudg-
ment standard should apply only in that context. Id., at 24. 
The District's reading of Monahan is diffcult to square 
with what that opinion said. The Monahan court's discus-
sion of Section 504 was inextricably bound with concomitant 
references to the IDEA. And its reasoning, at bottom, was 
grounded—much like this Court's in Smith—in an effort to 
strike what it believed was the appropriate balance between 
the two statutes. See Monahan, 687 F. 2d, at 1170–1171. 
The District's take on Monahan is simply neither the most 
natural nor the most persuasive one. Besides, it conficts 
with the Eighth Circuit's own interpretation of its precedent, 
including in the case before us. See 96 F. 4th, at 1062, n. 2 
(noting that Monahan's rule was rooted in “specula[tion] that 
Congress intended the IDEA's predecessor to limit Section 
504's protections”); see, e. g., I. Z. M. v. Rosemount–Apple 
Valley–Eagan Public Schools, 863 F. 3d 966, 973 (1996); 
Hoekstra v. Independent School Dist. No. 283, 103 F. 3d 624, 
627 (1996) (“In applying a bad faith/gross misjudgment 
standard to § 504, the Monahan court reasoned that such a 
standard harmonizes the [IDEA] and § 504.”). So too with 
the understandings of other Courts of Appeals. See, e. g., 
Knox County v. M. Q., 62 F. 4th 978, 1002 (CA6 2023). 
C 
Perhaps sensing the likely fate of Monahan's asymmetric 
rule, the District no longer seeks to defend it. See Tr. of 
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350 A. J. T. v. OSSEO AREA SCHOOLS, INDEPENDENT 
SCHOOL DIST. NO. 279 
Opinion of the Court 
Oral Arg. 88 (stating that “the parties are in radical agree-
ment” on the question “whether you have a different stand-
ard in the educational context” (counsel for respondents)); 
id., at 78 (agreeing “there's no two-tier test” (same)). The 
District now contends instead that bad faith or gross mis-
judgment is “the correct standard across the board” for 
injunctive relief and damages, “both in schools and out.” 
Brief for Respondents 2 (emphasis added). The “infrmity,” 
the District says, is not “with Monahan's original interpre-
tation,” but with “the logic of” later cases that imposed 
lower intent standards in other disability discrimination con-
texts. Id., at 24. 
“As a general rule,” however, “we do not decide issues” 
that were not “resolved below” and are “outside the ques-
tio[n] presented by the petition for certiorari.” Glover v. 
United States, 531 U. S. 198, 205 (2001). The District's posi-
tion fails on both counts. A. J. T. asked us to review the 
“uniquely stringent `bad faith or gross misjudgment' stand-
ard,” which she characterized throughout her petition as an 
“arbitrar[y] depart[ure] from the more lenient standards that 
all courts—including the Eighth Circuit—apply to ADA and 
Rehabilitation Act claims brought by plaintiffs outside the 
school setting.” Pet. for Cert. i; see also, e. g., id., at 32. 
For its part, the District never suggested at the certiorari 
stage that it thought this case was about anything other than 
the two-tiered approach set forth in Monahan. 
We agree with A. J. T. that “it would be unfair at this 
point” to allow the District “to switch gears and seek a rul-
ing from us that the standard should be” bad faith or gross 
misjudgment “across the board.” Norfolk Southern R. Co. 
v. Sorrell, 549 U. S. 158, 165 (2007); see Tr. of Oral Arg. 101. 
We will not entertain the District's invitation to inject into 
this case signifcant issues that have not been fully pre-
sented. See South Central Bell Telephone Co. v. Alabama, 
526 U. S. 160, 171 (1999); Sorrell, 549 U. S., at 165. The 
question before us “is a narrow one, and we see no need to 
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Cite as: 605 U. S. 335 (2025) 351 
Thomas, J., concurring 
do more than answer that question in today's decision.” Id., 
at 171−172. 
* * * 
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 chal-
lenges 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. 
It is so ordered. 
Justice Thomas, with whom Justice Kavanaugh joins, 
concurring. 
The Court's opinion correctly resolves the question pre-
sented. I write separately to note that in an appropriate 
case, I would be willing to consider the additional issues 
raised by the respondents (collectively, the District) at the 
merits stage. Although those issues were not properly be-
fore us in this case, they are important and merit our atten-
tion in the future. 
We granted certiorari to decide whether Title II of the 
Americans with Disabilities Act and Section 504 of the Reha-
bilitation Act require disabled schoolchildren to satisfy a 
“uniquely stringent” standard when seeking relief under 
those statutes. Pet. for Cert. i. In other words, we took 
the case to decide whether Title II and Section 504 permit 
courts to subject one subset of plaintiffs to a higher legal 
standard than other plaintiffs, simply because their claims 
arise in the school context. At the merits stage, both sides 
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352 A. J. T. v. OSSEO AREA SCHOOLS, INDEPENDENT 
SCHOOL DIST. NO. 279 
Thomas, J., concurring 
agreed that the answer must be “no.” Brief for Petitioner 
2–3; Brief for Respondents 2; see also Tr. of Oral Arg. 78. 
The Court today agrees with the parties, holding that school-
related claims are subject to the same legal standards as 
other claims. Ante, at 345. 
At the merits stage, the District asked us to go beyond 
the question presented. Specifcally, it urged us to clarify 
the particular standards that should apply in Title II and 
Section 504 litigation. In most courts of appeals, the opera-
tive 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. E. g., Hall v. Higgins, 77 F. 4th 
1171, 1180–1181 (CA8 2023); Midgett v. Tri-County Metro-
politan Transp. Dist. of Ore., 254 F. 3d 846, 851 (CA9 2001). 
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. 
E. g., Hall, 77 F. 4th, at 1180–1181; Silberman v. Miami Dade 
Transit, 927 F. 3d 1123, 1134 (CA11 2019). The District 
challenges the no-intent standard, arguing that intent to dis-
criminate should be required to establish a violation or to 
obtain any kind of relief. It presses its theory on both stat-
utory and constitutional grounds. 
To start, the District argues that the plain text of the un-
derlying statutes prohibit only intentional discrimination. 
Section 504 states that individuals with disabilities shall not 
“be excluded from the participation in, be denied the benefts 
of, or be subjected to discrimination” under any federally 
funded “program or activity” “solely by reason of her or his 
disability.” 29 U. S. C. § 794(a). Title II provides that indi-
viduals with disabilities shall not, “by reason of such disabil-
ity, be excluded from participation in or be denied the bene-
fts of the services, programs, or activities of a public entity, 
or be subjected to discrimination by any such entity.” 42 
U. S. C. § 12132. The District asserts that this statutory 
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Cite as: 605 U. S. 335 (2025) 353 
Thomas, J., concurring 
language—which prohibits “discrimination” “by reason of” 
disability—requires a showing of intent to discriminate be-
fore a violation can be established. 
Relatedly, the District contends that the underlying stat-
utes do not permit one standard for damages and another 
standard for injunctive relief. Title II incorporates the 
“remedies, procedures, and rights set forth in [Section 504].” 
§ 12133. And, Section 504, in turn, incorporates the “reme-
dies, procedures, and rights set forth in title VI” of the Civil 
Rights Act. 29 U. S. C. § 794a(a)(2). Title VI “prohibits 
only intentional discrimination.” Alexander v. Sandoval, 
532 U. S. 275, 280 (2001); accord, Students for Fair Admis-
sions, Inc. v. President and Fellows of Harvard College , 600 
U. S. 181, 288–290 (2023) (Gorsuch, J., concurring). This 
Court has held that private individuals thus may “not re-
cover compensatory damages under Title VI” unless they 
prove “intentional discrimination.” Sandoval, 532 U. S., at 
282–283. The District argues that if the incorporation of 
Title VI's rights and remedies requires intent for an award 
of damages, it should equally require intent for an award of 
injunctive relief. I share the District's skepticism that the 
same statutory language can mean two different things de-
pending on the relief sought. 
The District also raises a constitutional objection, arguing 
that the Constitution compels a plaintiff to prove intent to 
discriminate before a court may fnd a violation of Title II 
or Section 504 or award any kind of relief. See also Brief 
for State of Tennessee et al. as Amici Curiae 17–23 (arguing 
that constitutional considerations “weigh against Petitioner's 
no-intent reading” (boldface deleted)). Here too, I think the 
District may have a point. 
Congress enacted Section 504 pursuant to the so-called 
Spending Clause. “We have repeatedly characterized . . . 
Spending Clause legislation as `much in the nature of a con-
tract: in return for federal funds, the [recipients] agree to 
comply with federally imposed conditions.' ” Barnes v. Gor-
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354 A. J. T. v. OSSEO AREA SCHOOLS, INDEPENDENT 
SCHOOL DIST. NO. 279 
Thomas, J., concurring 
man, 536 U. S. 181, 186 (2002). “Just as a valid contract re-
quires offer and acceptance of its terms, `[t]he legitimacy of 
Congress' power to legislate under the spending power . . . 
rests on whether the [recipient] voluntarily and knowingly 
accepts the terms of the “contract.” ' ” Ibid. Thus, this 
Court has held that “if Congress intends to impose a condi-
tion on the grant of federal moneys, it must do so unambigu-
ously.” Pennhurst State School and Hospital v. Halder-
man, 451 U. S. 1, 17 (1981). But, the District argues, 
Section 504 unambiguously covers only intentional discrimi-
nation; nothing in the text conveys Congress's intent to im-
pose liability on schools for unintentional discrimination. 
The District tells us that a no-intent violation of Title II 
is even more dubious. As an initial matter, the District ob-
serves, it is unclear what constitutional authority Congress 
has to require a public school, by way of an injunction, to 
take an affrmative action such as providing additional in-
struction to a student. Congress enacted the ADA under its 
“power to enforce the fourteenth amendment and to regulate 
commerce.” 42 U. S. C. § 12101(b)(4). But, the Commerce 
Clause does not give Congress sweeping power to protect 
“the learning environment” in schools. United States v. 
Lopez, 514 U. S. 549, 564 (1995). And, the Fourteenth 
Amendment does “not requir[e]” schools to “make special ac-
commodations for the disabled.” Board of Trustees of Univ. 
of Ala. v. Garrett, 531 U. S. 356, 367 (2001). Instead, it pro-
hibits only conduct that lacks a rational basis, such as deci-
sions motivated by a “ `bare . . . desire to harm.' ” Cleburne 
v. Cleburne Living Center, Inc., 473 U. S. 432, 447 (1985). 
The District contends that Title II, which targets “State 
[and] local government[s],” § 12131(1)(A), cannot be read to 
“ `compe[l]' ” States to “ `expend . . . state funds' ” to accom-
modate people with disabilities “in accordance with federal 
standards.” See Murphy v. National Collegiate Athletic 
Assn., 584 U. S. 453, 463, 476 (2018). After all, the Constitu-
tion “has never been understood to confer upon Congress the 
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Page Proof Pending Publication
Cite as: 605 U. S. 335 (2025) 355 
Sotomayor, J., concurring 
ability to require the States to govern according to Congress' 
instructions.” New York v. United States, 505 U. S. 144, 162 
(1992). In the District's view, requiring a plaintiff to prove 
intent to discriminate before fnding a violation or award-
ing an injunction is necessary to mitigate these anti-
commandeering concerns. 
I express no defnitive 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. See 
this Court's Rule 14.1(a). 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 stat-
utes is an issue of national importance, and the District has 
raised serious arguments that the prevailing standards are 
incorrect. 
Of course, this Court's resolution of these issues could have 
signifcant ramifcations for both disability law and discrimi-
nation law more generally. See Reply for Petitioner 24 (ex-
plaining that adopting the District's position would “cause a 
sea change in disability law”). That these issues are conse-
quential is all the more reason to wait for a case in which 
they are squarely before us and we have the beneft of adver-
sarial briefng. Until then, I hope lower courts will care-
fully consider whether the existing standards comport with 
the Constitution and the underlying statutory text. 
Justice Sotomayor, with whom Justice Jackson joins, 
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 cor-
rect standard for all disability discrimination claims under

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356 A. J. T. v. OSSEO AREA SCHOOLS, INDEPENDENT 
SCHOOL DIST. NO. 279 
Sotomayor, J., concurring 
Title II and Section 504 of those Acts. See ante, at 349–351. 
I write separately, however, to highlight a foundational faw 
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.' ” Brief for Respondents 11–12, 16–17. That is 
incorrect. The statutes' text and history, as well as this 
Court's precedent, foreclose any such purpose requirement. 
Recall that Title II of the ADA provides that “no qualifed 
individual with a disability shall, by reason of such disability, 
be excluded from participation in or be denied the benefts 
of the services, programs, or activities of a public entity, or 
be subjected to discrimination by any such entity.” 42 
U. S. C. § 12132 (emphasis added). The Rehabilitation Act's 
similarly worded prohibition uses the same “by reason of” 
language, with the modifer “solely.” 29 U. S. C. § 794(a).* 
That statutory language contains no reference to improper 
purpose. To the contrary, the phrase “by reason of” re-
quires no more than a causal link between the individual's 
disability and her “exclu[sion] from” participating in or re-
ceiving the benefts of a covered service, program, or activ-
ity. Ibid.; 42 U. S. C. § 12132. That is the ordinary meaning 
of the phrase “by reason of.” See Merriam-Webster's Dic-
tionary (11th ed. 2025), https://www.merriam-webster.com/ 
dictionary/ by%20reason%20of (defning “by reason of” as 
“because of: due to”); Merriam-Webster's Collegiate Diction-
ary 101 (10th ed. 1996) (defning “because of” as “by reason 
of”); Webster's Third New International Dictionary 194 
(1971) (same). It is also the reading this Court has afforded 
*Section 504 of the Rehabilitation Act provides: “No otherwise qualifed 
individual with a disability in the United States . . . shall, solely by reason 
of her or his disability, be excluded from the participation in, be denied 
the benefts of, or be subjected to discrimination under any program or 
activity receiving Federal fnancial assistance or under any program or 
activity conducted by any Executive agency or by the United States 
Postal Service.” 29 U. S. C. § 794(a).

Cite as: 605 U. S. 335 (2025) 357 
Sotomayor, J., concurring 
the statutory phrase on numerous occasions. See, e. g., 
Husted v. A. Philip Randolph Institute , 584 U. S. 756, 769 
(2018) (“The phrase `by reason of' denotes some form of cau-
sation”); University of Tex. Southwestern Medical Center v. 
Nassar, 570 U. S. 338, 350 (2013) (describing “ `by reason of' ” 
as another way to say “ `because,' ” which indicates a 
“ `causal relationship' ”). 
Persons with disabilities can, of course, lose access to bene-
fts and services “by reason of,” or “because of,” their disabil-
ities absent any invidious animus or purpose. Stairs may 
prevent a wheelchair-bound person from accessing a public 
space; the lack of auxiliary aids may prevent a deaf person 
from accessing medical treatment at a public hospital; and 
braille-free ballots may preclude a blind person from voting, 
all without animus on the part of the city planner, the hospi-
tal staff, or the ballot designer. See, e. g., Tennessee v. Lane, 
541 U. S. 509, 514 (2004) (Title II claim brought by paraplegic 
individual who was forced to “craw[l] up two fights of stairs 
to get to [a] courtroom”); Liese v. Indian River Cty. Hospital 
Dist., 701 F. 3d 334, 338, 340–341 (CA11 2012) (Section 504 
claim brought by deaf individual against hospital for failure 
to provide adequate methods to communicate with doctors 
before they performed a major surgery); National Federa-
tion of Blind v. Lamone, 813 F. 3d 494 (CA4 2016) (Title II 
and Section 504 claims regarding access for blind people to 
an absentee voting system). The statutes' plain text thus 
reaches cases involving a failure to accommodate, even 
where no ill will or animus toward people with disabilities 
is present. 
There can be no question, too, that the statutes impose an 
affrmative obligation on covered entities to provide reason-
able accommodations, undercutting any improper-purpose 
requirement. Title II of the ADA defnes a “ `qualifed indi-
vidual with a disability' ” to mean an individual who, with 
“reasonable modifcations to rules, policies, or practices, the 
removal of architectural, communication, or transportation 
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358 A. J. T. v. OSSEO AREA SCHOOLS, INDEPENDENT 
SCHOOL DIST. NO. 279 
Sotomayor, J., concurring 
barriers, or the provision of auxiliary aids and services,” is 
able to “mee[t] the essential eligibility requirements for the 
receipt of services or the participation in programs or activi-
ties provided by a public entity.” 42 U. S. C. § 12131(2) (em-
phasis added). A separate provision also contemplates that 
“a public entity under [Title] II” must provide “reasonable 
accommodation[s],” subject to certain exceptions. § 12201(h). 
For its part, Section 504 of the Rehabilitation Act makes 
clear that accommodations, such as architectural alterations, 
may be required “for the purpose of assuring program acces-
sibility” if alternative accommodations are not available. 29 
U. S. C. § 794(c). These affrmative obligations underscore 
that the statutes do not require improper purpose to prove 
liability. Entities can violate the Acts, for instance, by fail-
ing to install a wheelchair-accessible ramp, without any dis-
criminatory animus. 
The statutes' use of the passive voice (“no qualifed indi-
vidual with a disability shall, by reason of such disability, be 
excluded . . . ”) only reinforces that conclusion. 42 U. S. C. 
§ 12132; see 29 U. S. C. § 794(a). As this Court has recog-
nized, “Congress's use of the passive voice” often indicates a 
“focu[s] on an event that occurs without respect to a specifc 
actor,” and therefore without respect to any actor's purpose. 
Dean v. United States, 556 U. S. 568, 572 (2009). 
If there were any remaining doubt, the history and pur-
pose of the statutes further confrm that Congress never in-
tended to impose an ulterior-purpose requirement. As this 
Court recognized in Alexander v. Choate, 469 U. S. 287 
(1985), when Congress enacted the Rehabilitation Act, it 
“perceived” “[d]iscrimination against the handicapped” as 
“most often the product, not of invidious animus, but rather 
of thoughtlessness and indifference—of benign neglect.” 
Id., at 295; see also id., at 296 (collecting statements by legis-
lators describing the Act as a response to “ `neglect' ” of the 
handicapped). As a result, “much of the conduct that Con-
gress sought to alter in passing the Rehabilitation Act would 
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Cite as: 605 U. S. 335 (2025) 359 
Sotomayor, J., concurring 
be diffcult if not impossible to reach were the Act construed 
to proscribe only conduct fueled by a discriminatory intent.” 
Id., at 296–297. That observation applies with equal force 
to Title II of the ADA, which Congress modeled on Section 
504. Cf. Fry v. Napoleon Community Schools, 580 U. S. 
154, 159 (2017) (noting the two statutes impose the “same 
prohibition” on covered entities). 
Consider one of the paradigmatic applications of these two 
laws: ensuring the “elimination of architectural barriers” to 
provide access for individuals with disabilities. See Alexan-
der, 469 U. S., at 297 (describing this as “one of the central 
aims of the [Rehabilitation] Act”). Architectural barriers 
like stairs are rarely (if ever) “erected with the aim or intent 
of excluding the handicapped.” Ibid. Yet if respondents' 
novel rule were the law, ADA and Rehabilitation Act claim-
ants would have to show that a building's architect acted 
with “animus” toward those with disabilities in sketching out 
her designs. Brief for Respondents 16. It is hard to imag-
ine any architectural-barrier claim succeeding under such a 
standard. Indeed, the total universe of viable claims of that 
nature may well be a null set. Respondents' proposed 
improper-purpose requirement would thus eviscerate the 
core of both the ADA and Rehabilitation Act, leaving mil-
lions of our fellow citizens without the protections Con-
gress intended. 
* * * 
In short, there is good reason no court of appeals has 
adopted respondents' eleventh-hour argument. Congress 
was not naive to the insidious nature of disability discrimina-
tion when it enacted the ADA and Rehabilitation Act. It 
understood full well that discrimination against those with 
disabilities derives principally from “apathetic attitudes 
rather than affrmative animus.” Alexander, 469 U. S., at 
296. The resulting laws refect that understanding, and it is 
not the Judiciary's prerogative to override Congress's pol-
icy judgments. 
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Page Proof Pending Publication
Reporter’s Note 
The attached opinion has been revised to refect the usual publication 
and citation style of the United States Reports. The revised pagination 
makes available the offcial United States Reports citation in advance of 
publication. The syllabus has been prepared by the Reporter of Decisions 
for the convenience of the reader and constitutes no part of the opinion of 
the Court. A list of counsel who argued or fled briefs in this case, and 
who were members of the bar of this Court at the time this case was 
argued, has been inserted following the syllabus. Other revisions may 
include adjustments to formatting, captions, citation form, and any errant 
punctuation. The following additional edits were made: 
p. 340, line 7: “support” is changed to “supportive” 
p. 340, line 15: “§ 1414(d)(1)(B)” is changed to “§ 1414(d)(1)(A)(i)(II)(bb)” 
p. 358, line 3: “the” is inserted before “participation”

Retrieval chunks

• #1

  PRELIMINARY PRINT Volume 605 U. S. Part 2 Pages 335–359 OFFICIAL REPORTS OF THE SUPREME COURT June 12, 2025 REBECCA A. WOMELDORF reporter of decisions Page Proof Pending Publication NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to noti…

• #2

  dated A. J. T.'s condition by permitting her to avoid morning activities and instead receive evening instruction. But when A. J. T.'s family moved to Minnesota in 2015, her new school district—Osseo Area Public Schools, Independent District No. 279—denied her parents' repeated requests to include evening instructi…

• #3

  ant disregarded a strong likelihood that the challenged action would violate federally protected rights. Nothing in the text of the applicable substantive protections or remedial provisions of Title II of the ADA or Section 504 of the Rehabilitation Act suggests that claims based on educational services should be …

• #4

  on educational services as compared to other sorts of disability discrimi- nation claims, the Eighth Circuit effectively read the IDEA to implicitly limit the ability of disabled schoolchildren to vindicate their independent ADA and Rehabilitation Act rights, thereby making it more diffcult to secure the statutory…

• #5

  standard, the courts explained, applies uniquely in the educa- tional services context and requires a more demanding show- *Briefs of amici curiae urging reversal were fled for the Council of Parent Attorneys and Advocates et al. by Brian Wolfman, Regina Wang, and Selene A. Almazan-Altobelli; and for Rep. Tony Coe…

• #6

  entity, or be subjected to discrimination by any such entity.” 42 U. S. C. § 12132. Both Section 504 and Title II “authorize individuals to seek redress for violations of their substantive guarantees by bringing suits for injunctive relief or money damages.” Fry, 580 U. S., at 160; see 29 U. S. C. § 794a(a)(2); 4…

• #7

  1 The IDEA was previously called “the Education of the Handicapped Act.” Fry v. Napoleon Community Schools, 580 U. S. 154, 160, n. 1 (2017). Congress renamed the law in 1990. See ibid. We refer to the statute and its predecessor versions as the IDEA throughout this opinion. Page Proof Pending Publication Cite as:…

• #8

  hours of compensatory education and “add certain services to [A. J. T.'s] IEP, including at-home instruction from 4:30 p.m. to 6:00 p.m. each school day.” Ibid. The school district sought judicial review, and a Federal District Court affrmed. 2022 WL 4226097, *21 (Minn., Sept. 13, 2022). The court agreed with the…

• #9

  more” than mere non-compliance with the applicable federal statutes.' ” 96 F. 4th, at 1061 (frst quoting Monahan v. Ne- braska, 687 F. 2d 1164, 1171 (CA8 1982); then quoting B. M., 732 F. 3d, at 887; citation omitted). The panel explained that, while “A. J. T. may have established a genuine dispute about whether …

• #10

  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 dis- criminate. See, e. g., Hall v. Higgins, 77 F. 4th 1171, 1180– 1181 (CA8 2023); Midgett v. Tri-County Metropolitan Transp. Dist. of Ore., 2…

• #11

  disabilities. 29 U. S. C. § 794(a); 42 U. S. C. § 12132. There is no textual indication that the protections of either disabil- ity discrimination statute apply with lesser force to certain qualifed individuals bringing certain kinds of claims. Nor do the applicable remedial provisions suggest any such distinctio…

• #12

  petence of courts to make judgments in technical felds.” Ibid. (“So long as the state offcials involved [did not] depart grossly from accepted standards among educational profes- sionals, we cannot believe that Congress intended to create liability under § 504.”). B The Monahan court was not alone in its instinc…

• #13

  modated” through the IDEA's “carefully tailored scheme.” Id., at 1012. Congress apparently did not agree. Within two years, it enacted a new provision of the IDEA, “overturn[ing]” Smith and “ `reaffrm[ing] the viability' of federal statutes like the ADA or Rehabilitation Act `as separate vehicles,' no less in- t…

• #14

  solely on Section 504's text, rather than anything to do with 6 Because we address only the application of the heightened bad faith or gross misjudgment standard of intent to education related ADA and Rehabilitation Act claims, our opinion should not be read to speak to any other showing that a plaintiff must make…

• #15

  rule, the District no longer seeks to defend it. See Tr. of Page Proof Pending Publication 350 A. J. T. v. OSSEO AREA SCHOOLS, INDEPENDENT SCHOOL DIST. NO. 279 Opinion of the Court Oral Arg. 88 (stating that “the parties are in radical agree- ment” on the question “whether you have a different stand- ard in the…

• #16

  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 chal- lenges on a daily basis. We hold today that those challenges do not include havi…

• #17

  intentional discrimination. E. g., Hall v. Higgins, 77 F. 4th 1171, 1180–1181 (CA8 2023); Midgett v. Tri-County Metro- politan Transp. Dist. of Ore., 254 F. 3d 846, 851 (CA9 2001). But, to obtain compensatory damages, courts generally agree that a plaintiff must prove that the defendant was at least “deliberately…

• #18

  prove “intentional discrimination.” Sandoval, 532 U. S., at 282–283. The District argues that if the incorporation of Title VI's rights and remedies requires intent for an award of damages, it should equally require intent for an award of injunctive relief. I share the District's skepticism that the same statutor…

• #19

  Clause does not give Congress sweeping power to protect “the learning environment” in schools. United States v. Lopez, 514 U. S. 549, 564 (1995). And, the Fourteenth Amendment does “not requir[e]” schools to “make special ac- commodations for the disabled.” Board of Trustees of Univ. of Ala. v. Garrett, 531 U. S.…

• #20

  fully consider whether the existing standards comport with the Constitution and the underlying statutory text. Justice Sotomayor, with whom Justice Jackson joins, concurring. I join in full the Court's opinion, which holds that ADA and Rehabilitation Act claims regarding educational services are subject to the s…

• #21

  *Section 504 of the Rehabilitation Act provides: “No otherwise qualifed individual with a disability in the United States . . . shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefts of, or be subjected to discrimination under any program or activity receivin…

• #22

  vidual with a disability' ” to mean an individual who, with “reasonable modifcations to rules, policies, or practices, the removal of architectural, communication, or transportation Page Proof Pending Publication 358 A. J. T. v. OSSEO AREA SCHOOLS, INDEPENDENT SCHOOL DIST. NO. 279 Sotomayor, J., concurring barr…

• #23

  Page Proof Pending Publication Cite as: 605 U. S. 335 (2025) 359 Sotomayor, J., concurring be diffcult if not impossible to reach were the Act construed to proscribe only conduct fueled by a discriminatory intent.” Id., at 296–297. That observation applies with equal force to Title II of the ADA, which Congress …

• #24

  for the convenience of the reader and constitutes no part of the opinion of the Court. A list of counsel who argued or fled briefs in this case, and who were members of the bar of this Court at the time this case was argued, has been inserted following the syllabus. Other revisions may include adjustments to forma…