The Ninth Circuit Court of Appeals dismissed a legal challenge to a California school district's COVID-19 mask mandate, upholding a lower court's decision to reject the lawsuit brought by a mother and her teenage daughter.
In a memorandum decision filed Jan. 6, 2026, a three-judge panel affirmed the U.S. District Court for the Eastern District of California's dismissal of the case brought by pro se plaintiffs Desiree Dawn McGuire and her daughter, Cadence DeVault, against the Roseville Joint Union High School District.
The plaintiffs challenged the district's implementation and enforcement of face-covering requirements during the COVID-19 pandemic. Their lawsuit named multiple defendants, including the school district itself, the District Board of Trustees, several board members, former and interim superintendents, an assistant principal, and the assistant principal's secretary.
According to court documents, the plaintiffs filed a First Amended Complaint containing 17 causes of action. Nine claims were brought under state law, while eight were federal civil rights claims filed under 42 U.S.C. § 1983, alleging violations of the Fourth, Fifth, and Fourteenth Amendments to the U.S. Constitution.
The federal claims targeted all defendants, with the individual defendants sued in both their official and personal capacities. This approach sought to hold school officials personally liable for their roles in implementing and enforcing the mask requirements.
The case originated in the Eastern District of California, where District Judge Troy L. Nunley presided over the proceedings. The district court granted the defendants' motion to dismiss, leading to the plaintiffs' appeal to the Ninth Circuit.
The Ninth Circuit panel, composed of Circuit Judges Susan P. Graber Bennett, Bridget S. Bade, and Michelle T. Friedland, decided the case was suitable for resolution without oral argument, as permitted under Federal Rule of Appellate Procedure 34(a)(2). The panel unanimously concluded the case could be decided based on the written record alone.
The appellate court's decision came in the form of a memorandum disposition, which is marked as "not for publication" and carries limited precedential value. Under Ninth Circuit Rule 36-3, such dispositions are not considered binding precedent except in specific circumstances.
The lawsuit represents one of numerous legal challenges to COVID-19 health measures implemented by educational institutions across the United States during the pandemic. School districts nationwide faced lawsuits from parents and students who opposed mask mandates, arguing they violated constitutional rights or exceeded institutional authority.
The Roseville Joint Union High School District, located in Placer County, California, serves several communities in the Sacramento metropolitan area. Like many school districts across California, it implemented face-covering requirements as part of broader public health measures designed to reduce COVID-19 transmission in educational settings.
The plaintiffs' decision to represent themselves in both the district court and appellate proceedings highlights the pro se nature of their legal challenge. Self-represented litigants face significant procedural and substantive hurdles in federal court, particularly in complex constitutional litigation involving multiple defendants and claims.
The case number 23-16169 on appeal corresponds to the original district court case number 2:22-cv-00125-TLN-JDP, indicating the lawsuit was initially filed in 2022 when COVID-19 health measures remained a contentious issue in many educational settings.
The dismissal of this challenge aligns with the outcomes of many similar lawsuits filed against educational institutions' pandemic-related policies. Federal courts have generally been reluctant to second-guess public health measures implemented by school districts, particularly when such policies were adopted in response to public health emergencies.
The Ninth Circuit's decision effectively ends this particular legal challenge to the Roseville district's mask policy. The memorandum disposition provides no detailed analysis of the court's reasoning, as such decisions typically contain minimal discussion of the underlying legal issues.
For the Roseville Joint Union High School District and its officials, the appellate court's affirmation provides finality to this litigation chapter. The district successfully defended its pandemic-response policies through both the trial and appellate levels of federal court.
The outcome also demonstrates the challenges faced by individual plaintiffs seeking to challenge institutional policies in federal court, particularly when pursuing complex constitutional claims without legal representation. The case serves as an example of how procedural requirements and legal standards can present significant obstacles for pro se litigants in federal civil rights litigation.