GLBT Youth in Iowa Schools Task Force v. Reynolds
4:23-cv-00474
| S.D. Iowa | May 15, 2025Background
- Iowa Safe Schools and related plaintiffs challenged several provisions of Iowa Senate File 496, restricting instruction, programs, and notifications related to gender identity and sexual orientation in schools, as well as restrictions on certain books in school libraries.
- The challenged law prohibits school districts from providing any “program, curriculum, test, survey, questionnaire, promotion, or instruction relating to gender identity or sexual orientation” to K-6 students.
- Plaintiffs sought a preliminary injunction, arguing the restrictions violate constitutional rights, especially the First Amendment.
- The court previously enjoined the law for vagueness; the Eighth Circuit vacated and remanded for further analysis of potential narrower constructions.
- Upon reconsideration, the district court found parts of the law facially unconstitutional, while upholding others with narrow interpretations.
- Plaintiffs also challenged provisions requiring parental notification for affirming accommodations related to gender identity and the removal of books describing sex acts from school libraries.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prohibition on instruction/curriculum/test/survey/questionnaire re: gender identity/sexual orientation (K-6) | Overbroad, chills speech, impossible to comply, covers neutral references | Only applies to compulsory instruction; can be interpreted narrowly to avoid constitutional problems | Narrowed to bar only mandatory instruction with detailed/normative content; neutral/incidental references permitted; restriction upheld as so interpreted |
| Ban on programs and promotion re: gender identity/sexual orientation (K-6, e.g., GSAs) | Violates First Amendment by barring extracurricular clubs, associations, and related speech | Seeks to have it interpreted as applying to compulsory curriculum only | Overbroad and unconstitutional; enjoined as violation of students’ First Amendment rights |
| Parental notification of gender identity accommodations | Statute is unconstitutionally vague, chills speech, unclear what counts as an "accommodation" | Law is sufficiently clear and necessary for parental rights | Void for vagueness except where student requests different pronouns; only enforceable in that scenario |
| Removal of books describing sex acts from libraries | First Amendment violation; overbroad removal of protected texts | Necessary to keep inappropriate material from minors | Prior decision enjoining enforcement stands; restriction unenforceable |
Key Cases Cited
- Hazelwood Sch. Dist. v. Kuhlmeier, 484 U.S. 260 (schools have broad discretion over curriculum content)
- Bd. of Educ. of Westside Cmty. Sch. v. Mergens, 496 U.S. 226 (states set curriculum, courts defer on content)
- Gay & Lesbian Students Ass’n v. Gohn, 850 F.2d 361 (First Amendment prohibits viewpoint discrimination against student groups)
- Grayned v. City of Rockford, 408 U.S. 104 (vagueness doctrine limits arbitrary enforcement)
- Tinker v. Des Moines Indep. Cmty. Sch. Dist., 393 U.S. 503 (students retain constitutional rights at school)