Education for Americans with Disabilities: Reconciling IDEA with the 2008 ADA Amendments

This article examines the educational impact of the ADAAA by applying it to factual scenarios presented in ADA education cases from the late-1990s.

Each case illustrates the former analysis of an ADA claim, from defining disability to determine reasonable accommodations. The Analysis section of this article sets out a foreseeable shift in the analysis of an ADA claim after the ADAAA. Specifically, the focus will move away from a determination of whether a disability exists, which the ADAAA broadens. 

Instead, courts will place more emphasis on whether a school discriminated against or reasonably accommodated each student, regardless of a student's own mitigating measures for his achievement compared with an "average" student's performance. 18 The new analysis of an ADA claim is contrasted with the new analysis of an IDEA claim in light of Forest Grove. 19 Finally, this article highlights the unique challenges that public schools face as a result of the ADAAA and IDEA provisions, including accommodating a diverse population of abilities and disabilities.