John Doe v. State of South Carolina, 25-1787

South Carolina enacted a budget proviso barring transgender students from using multi-stall restrooms matching their gender identity in public schools, defining sex by birth anatomy/genetics and penalizing non-compliant schools financially.
"John Doe," a transgender high school student, was disciplined and eventually withdrew from in-person school rather than comply; his performance and well-being suffered online.
Doe and family sought re-enrollment and challenged the law, alleging Title IX and Equal Protection violations under Fourth Circuit precedent (Grimm).
The district court stayed the case pending Supreme Court action on a related case (West Virginia v. B.P.J.) and denied Doe's motions for injunctive relief without prejudice.
Doe appealed, seeking an injunction pending appeal, arguing the stay functionally denied urgent relief as the new school year began.
The Fourth Circuit considered jurisdiction, standing, and merits of preliminary relief amid ongoing uncertainty about forthcoming Supreme Court rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court has jurisdiction to review the preliminary injunction denial and stay order	Denial/stay effectively refused needed urgent relief; merits reached	Denial/stay was without prejudice; no final appealable order	Jurisdiction upheld: effect was constructive denial
Whether Doe has standing to challenge the Proviso and appeal	Proviso harms are concrete, ongoing, and redressable	Standing lacking due to change in Proviso, procedural flaws	Standing found; Doe aggrieved by district court order
Whether an injunction pending appeal is warranted (Title IX/Equal Protection)	Grimm controls; Proviso likely violates Doe's rights	Grimm is unsettled; Proviso is materially different, SCOTUS pending	Injunction granted under binding circuit precedent
Whether appeal should be expedited	Urgency due to school year, ongoing harm	Normal timeline sufficient, injunction gives interim relief	Expedited appeal denied; normal schedule remains

Grimm v. Gloucester Cnty. Sch. Bd., 972 F.3d 586 (4th Cir. 2020) (holding bathroom policy requiring students to use facilities matching biological sex violated Equal Protection and Title IX)
Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (2008) (establishes four-factor test for preliminary injunctions)
Nken v. Holder, 556 U.S. 418 (2009) (clarifies the two most critical injunction factors: likelihood of success and irreparable harm)
Lujan v. Defs. of Wildlife, 504 U.S. 555 (1992) (sets standing requirements: injury in fact, traceability, redressability)
Carson v. Am. Brands, Inc., 450 U.S. 79 (1981) (defines interlocutory appeal rights under 28 U.S.C. § 1292(a)(1))
Spokeo, Inc. v. Robins, 578 U.S. 330 (2016) (explains standards for injury under Article III standing)