The U.S. Court of Appeals for the Ninth Circuit issued a significant First Amendment ruling Wednesday, reversing a lower court decision and blocking enforcement of Idaho's Children's School and Library Protection Act pending further litigation.
In *Northwest Association of Independent Schools v. Labrador*, the three-judge panel unanimously reversed the U.S. District Court for the District of Idaho's denial of a preliminary injunction against House Bill 710, which restricts schools and public libraries from making certain content deemed "harmful" available to minors.
The appellants include the Northwest Association of Independent Schools, Sun Valley Community School Inc., Foothills School of Arts and Sciences Inc., and several other organizations and individuals, including parents acting on behalf of minor children. They challenged Idaho Attorney General Raul Labrador and county prosecutors Jan M. Bennetts of Ada County and Matthew E. Fredback of Blaine County.
Circuit Judge Milan D. Smith Jr. authored the opinion for the panel, which also included Circuit Judges Jacqueline H. Nguyen and Holly A. Thomas. The court heard oral arguments in Portland, Oregon, on Nov. 3, 2025, and filed its decision Jan. 29, 2026.
The case centers on constitutional challenges to H.B. 710, with plaintiffs arguing the statute violates the First Amendment through overbroad restrictions on speech and expression. The law prohibits schools and public libraries from providing access to materials deemed harmful to minors, but plaintiffs contend the restrictions exceed constitutional boundaries.
District Judge Amanda K. Brailsford had initially denied the plaintiffs' request for preliminary relief, finding their arguments insufficient to warrant blocking enforcement of the state law. However, the Ninth Circuit disagreed with this assessment and determined that the plaintiffs had demonstrated the necessary legal standards for injunctive relief.
The appeal specifically focused on First Amendment overbreadth theories, which challenge laws that restrict more speech than the Constitution permits. Under this legal doctrine, a statute may be invalidated if it prohibits a substantial amount of protected speech relative to its legitimate applications.
The coalition of plaintiffs represents diverse stakeholders in Idaho's educational and library systems. The Northwest Association of Independent Schools serves private educational institutions across the region, while individual schools like Sun Valley Community School and Foothills School of Arts and Sciences have direct operational concerns about compliance with the new restrictions.
Community organizations including the Community Library Association and Collister United Methodist Church joined the challenge, along with individual parents who argued the law affects their children's access to educational materials and library resources.
The case highlights ongoing national tensions over content restrictions in schools and libraries, particularly regarding materials that address topics some consider inappropriate for minors. Similar legislation has been enacted or proposed in multiple states, leading to various legal challenges across federal circuits.
Idaho's H.B. 710 represents part of a broader legislative trend aimed at regulating access to certain books and materials in educational and public library settings. Supporters argue such measures protect children from inappropriate content, while critics contend they constitute censorship that violates constitutional principles.
The Ninth Circuit's decision to grant preliminary injunctive relief suggests the court found plaintiffs demonstrated a likelihood of success on their constitutional claims, irreparable harm absent an injunction, and that the balance of hardships favored blocking enforcement during litigation.
Preliminary injunctions require plaintiffs to show they will likely prevail on the merits of their claims and suffer irreparable injury if relief is not granted. Courts also consider whether granting the injunction serves the public interest and whether the balance of hardships between parties favors the moving party.
The ruling remands the case to the district court for further proceedings consistent with the appeals court's opinion. This means the lower court must reconsider the preliminary injunction motion under the legal standards articulated by the Ninth Circuit.
While the decision blocks enforcement of H.B. 710 during ongoing litigation, it does not constitute a final ruling on the law's constitutionality. The case will continue in district court, where both sides will have opportunities to present evidence and arguments on the underlying First Amendment claims.
The state of Idaho may seek further appellate review, potentially asking for rehearing before the full Ninth Circuit or petitioning the Supreme Court for certiorari, though such relief is discretionary and uncertain.
This decision adds to the growing body of federal court rulings addressing content restrictions in educational settings, providing guidance for similar challenges in other jurisdictions. The outcome will likely influence how courts evaluate the constitutionality of comparable state legislation targeting library and school materials.