Supreme Court Rules, Again, That Different Standards for Discrimination Plaintiffs Are Unconstitutional
The Court ruled unanimously in favor of a disabled teenage girl and her family, who faced a higher bar to prove that her school discriminated against her.
On Thursday, the Supreme Court unanimously ruled in favor of a teenage girl and her parents who are attempting to sue the girl's school district for alleged disability discrimination. The decision, which did not rule on the merits of the case, is similar to another recent unanimous ruling finding that courts cannot require different discrimination cases to meet different standards of proof to receive a favorable judgment.
The case revolves around a teenage girl with a rare form of epilepsy that severely impacts her physical and cognitive abilities. The girl, identified as "A. J. T." in court documents, has so many seizures each morning that she is unable to attend school before noon. According to her family's suit, the girl received additional evening instruction in her first school district. However, when the family moved to Minnesota, the girl's new school district refused to provide similar accommodations. Instead, she ended up only having a 4.25-hour school day, as opposed to the regular 6.5-hour school day other students received. When the district suggested cutting back her instructional time further, the family sued, claiming that the Minnesota school district's refusal to provide A. J. T. with enough instructional time violated the Americans with Disabilities Act (ADA) and the Rehabilitation Act.
However, two lower courts ruled against the family. The 8th Circuit ruled that simply failing to provide A. J. T. a reasonable accommodation wasn't enough to prove illegal discrimination. Rather, because the family was suing a school, they would be subject to a higher standard than plaintiffs suing other institutions. The family was told they had to prove that the school's behavior rose to the level of "bad faith" or "gross misjudgment."
The Supreme Court disagreed. In the Court's opinion, Chief Justice John Roberts wrote that disability discrimination "claims based on educational services should be subject to the same standards that apply in other disability discrimination contexts," adding that "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."
In a concurring opinion, Justice Sonia Sotomayor reiterated how nonsensical the 8th Circuit's higher standard for educational disability discrimination claims was, noting that some of the most obvious forms of disability discrimination do not involve bad faith or misjudgment against the disabled.
"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 hospital staff, or the ballot designer," she wrote. "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."
Last week, the Court reached a similar decision, ruling in favor of a straight woman who wanted to sue her employer for sexual orientation–based discrimination but faced a heightened standard of proof because she was a "majority group" plaintiff. In that case, the Court also unanimously ruled that forcing some plaintiffs to clear a higher bar to prove discrimination was unconstitutional and unsupported by federal antidiscrimination law.
