Supreme Court Rejects Higher Damage Standard in Educational Disability Cases
The Supreme Court recently issued a significant decision clarifying the standard required to establish compensatory damages in educational discrimination cases involving students with disabilities. The ruling specifically overturned a historical precedent in educational contexts that had imposed a tougher "bad faith or gross misjudgment" standard on plaintiffs seeking monetary relief.
The Two Standards: Relief vs. Damages
Outside of the educational setting, establishing a violation of disability statutes and obtaining injunctive relief (such as ordering a change in action) requires demonstrating three key elements:
1. A disability exists.
2. The individual meets the standard for eligibility under the statute.
3. Discrimination occurred.
Crucially, proving intent to discriminate is not necessary for injunctive relief.
However, when seeking compensatory damages (monetary relief) under these same statutes, a showing of intentional discrimination is generally required. This intent is typically satisfied by the deliberate indifference standard.
The Deliberate Indifference Standard
The deliberate indifference standard requires a showing that the defendant disregarded a strong likelihood that the challenged action would violate a federally protected right. This is considered a lesser standard than having to prove "bad faith or gross misjudgment."
Historically, courts applying these standards in the educational context had applied the higher "bad faith or gross misjudgment" standard when considering claims for compensatory damages. This is the standard the recent Supreme Court decision challenged.
The Underlying Case: A Teenage Girl with Epilepsy
The Supreme Court's decision arose from a claim brought by the parents of a teenage girl, A.J.T., who suffers from a severe form of epilepsy. Her condition prohibits her from participating in her education before noon.
• First School District: A.J.T.'s first school district permitted her to attend classes starting at noon and provided evening instruction to compensate for the missed morning hours, ensuring she received the standard 6.5 hours of instruction.
• New School District: After A.J.T. moved, the new school district denied the requests for the same schedule. As a result, A.J.T. only received 4.25 hours of instruction daily.
The parents initially filed a complaint under the Individuals with Disabilities Education Act (IDEA). That process resulted in a decision that ordered the district to provide compensatory education and evening instruction.
The parents then sued the school district under Section 504 and the ADA, seeking a permanent injunction, reimbursement for costs, and compensatory damages.
The Legal Battle and the Supreme Court's Decision
The Federal District Court granted the school district’s motion for summary judgment on the damages claim. The Circuit Court upheld this decision, arguing that the school district's failure to provide a reasonable accommodation was not enough to establish the prima facie case of deliberate indifference, which, in the educational context, required the higher proof of "bad faith or gross misjudgment."
The parents appealed, and the Supreme Court granted certiorari.
In its analysis, the Supreme Court overturned the lower court's decision, rejecting the rationale for applying a unique, higher standard for compensatory damages in the educational context than that applied in all other contexts.
The Court found that the historically higher "bad faith or gross misjudgment" standard could not be reconciled with the provisions of the IDEA, specifically 20 U.S.C. \S 1415 (l), which states:
"Nothing in the IDEA 'be construed to restrict or limit the rights procedures and remedies available' under other laws."
The Supreme Court vacated the lower court's judgment and remanded the case, instructing the lower courts to apply the standard now established by the Supreme Court, the deliberate indifference standard,when considering the compensatory damages claim.
This ruling makes it clear that students seeking compensatory damages for intentional discrimination under Section 504 and the ADA in the educational context must meet the same standard as plaintiffs in other areas: deliberate indifference.
