A.J.T. v. Osseo Area Schools, ISD No. 279
Case Overview
A.J.T., a student with a disability, sued her school district under the ADA and Section 504 of the Rehabilitation Act after she was denied accommodations that would have allowed her to attend school during daytime hours. The Supreme Court addressed what standard governs ADA and Section 504 claims by disabled students when the claim also implicates the Individuals with Disabilities Education Act's administrative exhaustion requirement.
The Facts
A.J.T. has a rare condition that makes sunlight harmful, requiring her to attend school during evening hours. The school district initially accommodated her, then changed her schedule, forcing her to choose between attending at times harmful to her health or not attending at all. Her parents sued under the ADA and Section 504, seeking injunctive relief. The district argued the suit was barred because the family had not exhausted IDEA's administrative remedies.
The Application
The Court applied the Fry gravamen test to distinguish A.J.T.'s accommodation claim from a traditional FAPE denial claim, focusing on whether IDEA's administrative process could remedy the alleged violations. Because A.J.T. sought evening-hour accommodations for her photosensitivity condition rather than challenging the adequacy of her educational program itself, the gravamen was disability discrimination and equal access, not FAPE denial. This distinction meant IDEA exhaustion did not apply, allowing her ADA and Section 504 claims to proceed directly to federal court, establishing that disability discrimination claims seeking equal participation in existing programs are not automatically barred by the exhaustion requirement.
The Conclusion
**A.J.T. refines the Fry framework for determining when disabled students must exhaust IDEA administrative remedies before bringing ADA or Section 504 claims in federal court.** The ruling affects the access of disabled students to federal court by determining how broadly the IDEA exhaustion requirement applies to claims that sound in disability discrimination rather than denial of FAPE specifically, with particular significance for students whose disabilities require accommodations beyond what IDEA's administrative process addresses.
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