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Fourth Circuit Upholds Montgomery County Schools’ Pronoun Policy in 2–1 Ruling

Judges treated the pronoun and confidentiality rules as neutral conditions of public employment.

Overview

  • The three-judge panel on January 28 affirmed a Maryland district court’s decision and rejected Kimberly Polk’s request for a preliminary injunction.
  • The ruling means Polk cannot take MCPS teaching assignments unless she follows the district’s requirement to use students’ chosen names and pronouns and to keep a student’s trans status confidential.
  • Judge Robert B. King wrote for the majority that the guidelines are neutral and generally applicable and that the speech at issue falls within a teacher’s official duties.
  • Judge J. Harvie Wilkinson III dissented, characterizing the policy as compelled speech and asserting Polk was likely to succeed on her free speech claim.
  • Polk’s attorney said they are considering an appeal to the full Fourth Circuit or the U.S. Supreme Court, and the decision is precedential across the circuit’s five states.