Mirabelli v. Bonta

CourtSupreme Court of the United States
DecidedMarch 2, 2026
Docket25A810
StatusPublished

This text of Mirabelli v. Bonta (Mirabelli v. Bonta) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mirabelli v. Bonta, (U.S. 2026).

Opinion

Per Curiam

SUPREME COURT OF THE UNITED STATES _________________

No. 25A810 _________________

ELIZABETH MIRABELLI, ET AL. v. ROB BONTA, ATTORNEY GENERAL OF CALIFORNIA, ET AL. ON APPLICATION TO VACATE INTERLOCUTORY STAY ORDER [March 2, 2026]

PER CURIAM. Before us is an application to vacate a Court of Appeals order staying a permanent injunction entered by a District Court on behalf of parents and teachers who claim that cer- tain California policies violate their rights under the Free Exercise Clause of the First Amendment and the Due Pro- cess Clause of the Fourteenth Amendment. The parents object that these policies prevent schools from telling them about their children’s efforts to engage in gender transition- ing at school unless the children consent to parental notifi- cation. The parents also take issue with California’s re- quirement that schools use children’s preferred names and pronouns regardless of their parents’ wishes. The teachers object to their compelled participation in the implementa- tion of the State’s policies. I This case began in the United States District Court for the Southern District of California in 2023 when two teach- ers sued seeking an exemption from their school district’s policies regarding students’ gender. During litigation, the school district claimed that state law, as interpreted by the California attorney general and Department of Education, required it to adopt these policies. So the teachers added state officials as defendants, and parents of California schoolchildren joined the lawsuit as plaintiffs. Relying on 2 MIRABELLI v. BONTA

their own experiences and guidance documents issued by state officials, plaintiffs alleged that California’s policies permitted disclosure of a student’s gender transitioning at school only if the student consented. Plaintiffs claimed that these policies violated their rights under the Free Exercise Clause of the First Amendment and the Due Process Clause of the Fourteenth Amendment. Two of the parent plaintiffs, John and Jane Poe, have re- ligious objections to gender transitioning but were not told by their daughter’s school when she began to present as a boy and use a male name and male pronouns during her seventh-grade year. In parent-teacher meetings, no one told the Poes about their daughter’s transitioning or re- ferred to her using the male name and pronouns that were used at school. At the beginning of their daughter’s eighth- grade year, she attempted suicide and was hospitalized. Only then did her parents learn from a doctor that she had gender dysphoria and had been presenting as a boy at school. Just months after being discharged, the Poes’ daughter was rehospitalized and held there involuntarily because she was at risk for self-harm. At a new school in ninth grade, she once again began identifying as a boy. Contrary to the Poes’ instructions, teachers and school offi- cials continued to use a male name and pronouns for their daughter, citing their obligations under California state law. The Poes have placed their daughter in therapy and obtained psychiatric care for her. Like the Poes, plaintiffs John and Jane Doe object to gen- der transitioning, but since fifth grade, their daughter has sometimes identified as a boy. When their daughter was in seventh grade, the Does confronted the school principal about their daughter’s transitioning. They believed the school was using a male name and pronouns for their daughter behind their backs. The principal explained that state law prohibited the school from sharing information about a child’s transitioning with the child’s parents Cite as: 607 U. S. ____ (2026) 3

without the child’s consent. The Does believed that the risk of leaving their daughter in that school was too great, so they transferred their daughter to a new public school be- cause sending her to a private school was financially and logistically infeasible. The Does have also placed their daughter in therapy. In 2025, defendants asserted that the guidance docu- ments on which plaintiffs had relied were no longer opera- tive and that the claims against certain state defendants should be dismissed as moot. But the State had promul- gated a new required training curriculum that similarly di- rected teachers not to tell parents about their children’s gender identity without the children’s consent. Defendants then withdrew their mootness argument, and the District Court declined to impose sanctions. Later, plaintiffs sought classwide relief, and the District Court certified a class with separate subclasses for parents and teachers. One subclass of parents comprises all those who object to the challenged policies, while a separate sub- class is limited to those who seek a religious exemption. App. to Emergency Application 90a (App.). Two similar subclasses of teachers were also certified. Id., at 89a–90a. After discovery, the court granted summary judgment for all plaintiffs and entered a permanent injunction in their favor. The injunction prevents the schools from “mislead- ing” parents about their children’s gender presentation at school and their social transitioning efforts. Id., at 24a. It also requires the schools to follow parents’ directions re- garding their children’s names and pronouns. And it com- pels defendants to include in state-created or approved in- structional materials a notice of the rights protected by the injunction. The Ninth Circuit granted defendants’ motion to stay the injunction pending appeal. It began by raising procedural objections to the District Court’s injunction. It claimed that the District Court had granted class certification without 4 MIRABELLI v. BONTA

undertaking the “ ‘rigorous analysis’ ” required by Federal Rule of Civil Procedure 23. App. 7a (quoting Wal-Mart Stores, Inc. v. Dukes, 564 U. S. 338, 351 (2011)). And it stated that the injunction appeared to be overly broad be- cause it “covers every parent of California’s millions of pub- lic school students and every public school employee in the state.” App. 6a. As a result, it opined, the injunction seemed to grant relief to uninjured class members who lacked Article III standing. The Ninth Circuit also expressed doubts about the Dis- trict Court’s decision on the merits. On the free exercise issue, it relied on a not-precedential Sixth Circuit decision and brushed aside Mahmoud v. Taylor, 606 U. S. 522 (2025), as “a narrow decision focused on uniquely coercive ‘curricular requirements.’ ” App. 10a–11a (citing Doe No. 1 v. Bethel Local School Dist. Bd. of Educ., 2025 WL 2453836, *7 (CA6, Aug. 26, 2025)). The Ninth Circuit expressed skepticism about the parents’ and teachers’ Fourteenth Amendment due process claim because it viewed those claims as seeking to expand the protection afforded by es- tablished precedent. When the Ninth Circuit stayed the injunction, the par- ents and teachers filed this application seeking vacatur of the Ninth Circuit’s stay pending appeal. II We grant the application and vacate the stay with respect to the parents because this aspect of the stay is not “justi- fied under the governing four-factor test.” Alabama Assn. of Realtors v. Department of Health and Human Servs., 594 U. S. 758, 763 (2021) (per curiam) (citing Nken v. Holder, 556 U. S. 418, 434 (2009)). Likelihood of success on the merits. We conclude that the parents who seek religious exemptions are likely to succeed on the merits of their Free Exercise Clause claim. Califor- nia’s policies likely trigger strict scrutiny under that Cite as: 607 U. S. ____ (2026) 5

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Mirabelli v. Bonta, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mirabelli-v-bonta-scotus-2026.