Labrador v. Poe, 144 S.Ct. 921

Idaho enacted the Vulnerable Child Protection Act in 2023 to regulate medical treatments intended to alter a child’s sex, including surgeries and puberty blockers.
Two minors and their parents sued Idaho’s Attorney General, alleging the law would harm them by preventing access to gender-affirming care, and sought a preliminary injunction.
The district court issued a preliminary universal injunction, barring Idaho from enforcing any aspect of the law statewide while litigation proceeds.
Idaho appealed, specifically challenging the universal scope of the injunction, but not its applicability to the two plaintiff minors; the Ninth Circuit denied Idaho's request for a stay.
Idaho sought an emergency stay from the Supreme Court to allow the rest of the law to go into effect pending appeal, except as it concerns the two plaintiffs.
The Supreme Court granted the stay (in this context, partially narrowing the injunction), pending appeal and possible certiorari.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of Injunction: Universal vs. Plaintiff-Specific	Statewide ban is needed to protect plaintiffs from unconstitutional law	Injunction should only apply to named plaintiffs, not bar law enforcement statewide	Injunction stayed as to non-parties; limited to plaintiffs
Certworthiness/Emergency Stay	No need for emergency stay; no universal relief; merits not at issue	Scope of injunction is certworthy and warrants emergency intervention	Application of traditional stay factors justified stay
Traditional Equitable Principles	District court had discretion to craft broad relief to protect plaintiffs	Universal injunction exceeds traditional equitable bounds	Universal injunction exceeded equitable limits
Assessment of Harms and Public Interest	Plaintiff harm justifies broad relief	State is irreparably harmed by being barred from enforcing law statewide	State’s harm and public interest favored stay

Scripps-Howard Radio, Inc. v. FCC, 316 U.S. 4 (1942) (discussing historical authority for stay powers)
Nken v. Holder, 556 U.S. 418 (2009) (articulating standard for granting stays)
Califano v. Yamasaki, 442 U.S. 682 (1979) (remedial relief must be limited to addressing plaintiff’s injuries)
Guaranty Trust Co. v. New York, 326 U.S. 99 (1945) (federal equitable powers must be exercised in conformity with historic practice)
Boyle v. Zacharie & Turner, 31 U.S. 648 (1832) (equity powers historically limited to concrete party injuries)
Maryland v. King, 567 U.S. 1301 (2012) (irreparable harm to a state when statutes are enjoined)
Hollingsworth v. Perry, 558 U.S. 183 (2010) (certworthiness and stay standards in emergency applications)
Whole Woman’s Health v. Jackson, 594 U.S. _ (2021) (cautions against unreasoned emergency decisions)