Supreme Court Disability Discrimination Cases: A Practical Guide

Disability discrimination law in the United States has been shaped in large part by decisions of the U.S. Supreme Court. Through cases interpreting the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act, the Individuals with Disabilities Education Act (IDEA), and the Constitution, the Court has defined who is protected, what counts as discrimination, and how people with disabilities can enforce their rights.

This article offers an original, practical overview of influential Supreme Court disability discrimination cases, focused on what they mean for students, workers, and people seeking equal access to public services and programs.

1. Legal Foundations of Disability Discrimination Claims

Several key federal laws provide the framework for Supreme Court disability discrimination decisions:

• Americans with Disabilities Act (ADA) – A broad civil rights law that prohibits disability discrimination in employment (Title I), state and local government services and public transportation (Title II), and public accommodations (Title III). It was enacted in 1990 and amended in 2008 to broaden the definition of disability.
• Section 504 of the Rehabilitation Act of 1973 – Bans disability discrimination in programs or activities receiving federal financial assistance, including many schools, colleges, and hospitals.
• Individuals with Disabilities Education Act (IDEA) – Guarantees eligible children with disabilities the right to a free appropriate public education (FAPE) in the least restrictive environment.
• U.S. Constitution – Particularly the Fourteenth Amendment’s Equal Protection and Due Process Clauses, which have been used to challenge institutional conditions and government practices affecting people with disabilities.

Supreme Court cases often sit at the intersection of these laws, resolving conflicts about how broadly protections should be read and how they work together.

2. Who Counts as a “Qualified Individual with a Disability”?

The ADA and Section 504 protect only individuals who meet specific criteria.

• Under

  Title I of the ADA

  , a person must both have a disability and be a

  qualified individual

  , meaning they can perform the essential functions of the job, with or without reasonable accommodation.
• Under

  Title II and Section 504

  , the person must be a qualified individual with a disability in relation to the specific service, program, or activity at issue.

2.1 Retirees and the ADA: Limits on Employment Claims

One line of Supreme Court reasoning concerns whether people who are no longer working, or who do not seek a job, can bring ADA employment claims. In a recent case involving a retired employee who alleged discrimination in disability-related retirement benefits, the Court emphasized that plaintiffs must be qualified individuals at the time of the alleged discriminatory act.

Key points from that reasoning:

• To sue under ADA Title I, a plaintiff must show they held or sought a job when the employer allegedly discriminated against them.
• Being disabled alone is not enough; the statute ties protection to employment status and the ability to perform essential job functions with reasonable accommodation.
• However, the Court left room for retirees to challenge policies that were adopted or applied while they were still employed and qualified, if properly pleaded.

This line of decisions underscores that employment-based ADA rights are tightly connected to the employment relationship itself.

3. Education Rights: Disability Discrimination in Schools

Much Supreme Court disability litigation arises from K–12 schools and higher education. These cases often involve a combination of IDEA (which focuses on special education services) and broader antidiscrimination laws such as the ADA and Section 504.

3.1 Equal Standards for School-Based Discrimination Claims

In a 2025 decision involving a student with severe epilepsy, the Supreme Court addressed whether students must meet a higher intent standard than other plaintiffs when suing schools under the ADA and Section 504.

The lower courts required proof that the school acted with “bad faith or gross misjudgment”—a stringent test that went beyond what ADA and Section 504 plaintiffs must show in other contexts. The Supreme Court unanimously rejected this higher bar, holding that:

• Students bringing disability discrimination claims in education are entitled to the same legal standards as people challenging discrimination in employment, housing, or other settings.
• Courts should apply existing ADA and Section 504 principles, such as the deliberate indifference standard where appropriate, rather than creating school-specific hurdles.
• Students with disabilities already face “daunting challenges” and should not be subject to a more burdensome path to enforcement than other victims of discrimination.

Practically, this ruling makes it easier for students and families to pursue school-based disability discrimination claims, especially when schools refuse reasonable modifications to policies or practices.

3.2 Relationship Between IDEA and Civil Rights Claims

The same 2025 case clarified that winning or losing under IDEA does not dictate the outcome of separate ADA or Section 504 claims.

• IDEA focuses on whether the school provided a free appropriate public education (FAPE) tailored to the student’s needs.
• ADA and Section 504 look more broadly at whether the school discriminated on the basis of disability, for example by failing to reasonably modify policies, denying equal access, or retaliating for advocacy.
• Families may pursue both sets of claims, although they must often satisfy IDEA’s administrative exhaustion rules first.

As a result, a student can potentially prevail on ADA or Section 504 claims even if IDEA claims are resolved differently, and vice versa.

4. Access to Programs, Services, and Public Accommodations

Beyond schools and workplaces, the Supreme Court has considered how disability discrimination laws apply to public services and private entities that serve the general public.

4.1 Public Services and Transportation

Title II of the ADA and Section 504 require state and local governments to provide people with disabilities equal access to services, programs, and activities, unless doing so would fundamentally alter the nature of the program or impose undue burdens.

In this area, Supreme Court cases have addressed questions such as:

• How far government agencies must go to modify policies and physical structures to ensure accessibility.
• What counts as a reasonable modification in light of health and safety concerns.
• When a program’s eligibility criteria may unlawfully screen out people with disabilities.

4.2 Public Accommodations and Private Entities

Title III of the ADA covers private businesses that are open to the public, including restaurants, hotels, theaters, retail stores, and professional sports and entertainment venues.

Key principles from Supreme Court reasoning in this area include:

• People with disabilities are entitled to full and equal enjoyment of the goods and services offered, not merely physical entry.
• Reasonable modifications to policies may be required, unless they fundamentally alter the nature of the business or create an undue burden.
• Health and safety defenses (such as the “direct threat” concept) must be based on objective medical or scientific evidence, not stereotypes.

Cases involving sports, transportation, and public-facing services have helped clarify that accessibility is not limited to ramps and doorways; it also includes policies and practices that allow people with disabilities to participate equally.

5. Standards of Proof and Intent in Disability Discrimination

One of the most important themes in Supreme Court disability jurisprudence is the level of intent a plaintiff must prove to win a case. Different causes of action involve different standards:

• Intentional discrimination (e.g., deliberate exclusion or hostile treatment) often requires proof of discriminatory motive or deliberate indifference.
• Failure to accommodate may be treated as discrimination regardless of animus if a covered entity refuses reasonable modifications that are necessary to afford equal access.
• Constitutional claims under the Fourteenth Amendment require showing that the government’s conduct was at least deliberately indifferent to basic rights, and sometimes more.

5.1 Deliberate Indifference vs. Bad Faith

The 2025 school case drew attention to the difference between two common standards:

• Deliberate indifference – Often defined in federal civil rights law as knowledge of a substantial risk or serious need, followed by a failure to act reasonably to address it.
• Bad faith or gross misjudgment – A much higher threshold, implying dishonesty, extreme disregard, or conduct significantly beyond negligence.

The Supreme Court’s rejection of the “bad faith or gross misjudgment” standard for school-based ADA and Section 504 claims realigns education cases with mainstream civil rights doctrine.

6. Constitutional Protections and Institutional Conditions

Even before the ADA, the Supreme Court addressed conditions in institutions and the treatment of people with intellectual and developmental disabilities under the Constitution. These decisions continue to influence how courts interpret government obligations toward institutionalized individuals.

Important constitutional principles from these cases include:

• The right of institutionalized persons to be free from unsafe conditions and unreasonable physical restraints, grounded in substantive due process.
• Recognition that government actions based solely on irrational prejudice against people with intellectual disabilities can violate the Equal Protection Clause.
• An expectation that states provide minimally adequate training and care when they assume responsibility for people who cannot care for themselves.

These constitutional holdings complement, rather than replace, statutory protections like the ADA and Section 504. Together, they create overlapping layers of protection.

7. Practical Takeaways for Individuals and Advocates

Supreme Court disability discrimination cases can be complex, but several practical lessons emerge:

• Employment claims: To bring a Title I ADA claim, a person must have been employed or seeking a job at the time of the alleged discrimination and must be able to perform essential job duties with or without accommodation.
• Education claims: Students no longer face a special, higher standard to prove ADA or Section 504 discrimination in schools; courts should apply the same core principles used in other areas, including deliberate indifference where appropriate.
• Multiple statutes: A single situation may raise issues under IDEA, the ADA, Section 504, and constitutional law simultaneously. Outcomes under one statute do not automatically control the others.
• Documenting requests: Because many cases turn on whether an entity knew about a disability and a needed accommodation, written requests, medical documentation, and detailed notes can be crucial.
• Remedies: Depending on the statute and claim type, available remedies may include injunctive relief (orders to change policies), compensatory damages, and attorneys’ fees. Punitive damages are generally unavailable against public entities.

8. Frequently Asked Questions (FAQs)

Q1: Do I have to prove someone meant to discriminate against me to win a disability case?

Not always. In many ADA and Section 504 cases, especially those involving a failure to reasonably accommodate, plaintiffs may prevail by showing that a covered entity knew about the disability and the need for accommodation but failed to act reasonably—often analyzed under a deliberate indifference or similar standard—without proving outright hostility or bad faith.

Q2: Can a student bring both IDEA and ADA/Section 504 claims for the same situation?

Yes. IDEA addresses the adequacy of special education services (FAPE), while the ADA and Section 504 address broader disability discrimination. A family may pursue both, but often must follow IDEA’s administrative procedures before filing certain civil actions.

Q3: Are retirees ever protected by the ADA?

Retirees may still be protected by the ADA in some contexts (for example, when accessing public services or accommodations), but to sue under the employment provisions of Title I they generally must show that the alleged discrimination occurred while they were a qualified employee or job applicant. Merely being a former employee is not enough for a Title I claim.

Q4: What should I do if I think a school has discriminated against a student with a disability?

Document all communications, clearly request needed accommodations in writing, and consider using the school district’s grievance procedures. Families can also file complaints with the U.S. Department of Education’s Office for Civil Rights or pursue due process and litigation with the assistance of an attorney or advocacy organization.

Q5: How do Supreme Court decisions affect cases in lower courts?

Supreme Court interpretations of the ADA, Section 504, IDEA, and the Constitution are binding nationwide. Lower federal and state courts must apply those rulings when deciding similar cases, which is why each new Supreme Court decision can significantly change how disability discrimination claims are evaluated.

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Author

Sneha TeteBeauty & Lifestyle Writer

 

Sneha is a relationships and lifestyle writer with a strong foundation in applied linguistics and certified training in relationship coaching. She brings over five years of writing experience to waytolegal,  crafting thoughtful, research-driven content that empowers readers to build healthier relationships, boost emotional well-being, and embrace holistic living.

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