The Supreme Court of the United States dealt a blow to Planned Parenthood’s ideological agenda for school children this week, stating that parents “are entitled to a preliminary injunction” against an attempt to indoctrinate their young children with controversial materials on sexuality and gender — without allowing an opt-out.
Parents sued when the Montgomery County Board of Education in Maryland introduced controversial storybooks for routine classroom use (even among preschool-aged children) — and removed the option for parents to refuse.
Key Takeaways:
- In Mahmoud v. Taylor, the Supreme Court found in a 6-3 decision that “The parents are likely to succeed on their claim that the Board’s policies unconstitutionally burden their religious exercise.”
- The Court reaffirmed that it recognizes “the rights of parents to direct ‘the religious upbringing’ of their children.”
- The books required by the Board of Education under LGBTQ ‘inclusivity’ “impose upon children a set of values and beliefs that are “hostile” to their parents’ religious beliefs” and “exert upon children a psychological ‘pressure to conform’ to their specific viewpoints,” wrote the Court.
- Planned Parenthood and its Future of Sex Education (FoSE) coalition partners (SIECUS, Advocates for Youth) are behind the push to incorporate pro-abortion, “gender-affirming” materials into everyday classroom instruction (not just sex ed classes).
- The American Library Association is partnered with Planned Parenthood and others, recommending book lists that promote LGBTQ+-inclusive and often sexually-explicit materials to schools and libraries nationwide.
- The attempt to incorporate specific ideology without parental knowledge or permission isn’t limited to one school board or state; parents must be aware of the inclusion of such materials in classrooms and school libraries.
- 19 other state AGs joined Maryland’s AG in April, arguing that public schools have a right to promote “LGBTQ-inclusive” curricula without allowing parents to opt-out.
- The Supreme Court disagreed with this argument, describing how some of the books’ specific ideological views “present certain values and beliefs as things to be celebrated and certain contrary values and beliefs as things to be rejected.”
The Details:
The Court’s decision, penned by Justice Samuel Alito, stated that “the petitioners” were “a group of individual parents” who “come from diverse religious backgrounds and hold sincere views on sexuality and gender which they wish to pass on to their children….” The petitioners’ case relied “heavily on Wisconsin v. Yoder, 406 U. S. 205, in which the Court recognized that parents have a right ‘to direct the religious upbringing of their children’ and that this right can be infringed by laws that pose ‘a very real threat of undermining’ the religious beliefs and practices that parents wish to instill in their children.”
Alito noted, “In light of the record before us, we hold that the Board’s introduction of the “LGBTQ+-inclusive” storybooks—combined with its decision to withhold notice to parents and to forbid opt outs—substantially interferes with the religious development of their children and imposes the kind of burden on religious exercise that Yoder found unacceptable.” (p. 21)
A press release from The Becket Fund for Religious Liberty, a nonprofit legal institute, also quoted from the Court’s opinion:
… Justice Alito writing for the majority said, “Today’s decision recognizes that the right of parents ‘to direct the religious upbringing of their’ children would be an empty promise if it did not follow those children into the public school classroom.”
He went on to say that the Court “cannot agree” with lower courts who have ruled otherwise for over fifty years.
In its release, Becket stated that “the Montgomery County Board of Education announced “new ‘inclusivity’ books” in 2022 “for students in pre-K through fifth grade…. the books champion controversial ideology around gender and sexuality.”
Becket described two of the books (and curriculum instruction) this way:
… [O]ne book tasks three- and four-year-olds to search for images from a word list that includes “intersex flag,” “drag queen,” “underwear,” “leather,” and the name of a celebrated LGBTQ activist and sex worker.
Another book advocates a child-knows-best approach to gender transitioning, telling students that a decision to transition doesn’t have to “make sense.” Teachers are instructed to say doctors only “guess” when identifying a newborn’s sex anyway.
The School Board revoked notice and opt-outs for these storybooks, which violates Maryland law, the Board’s policies, and the advice of its own elementary school principals.
But the Court’s opinion also described some of the books in detail (pp. 22-27), noting that “other Americans wish to present a different moral message to their children. And their ability to present that message is undermined when the exact opposite message is positively reinforced in the public school classroom at a very young age.” (p. 25)
Alito spelled things out this way:
These books carry with them “a very real threat of undermining” the religious beliefs that the parents wish to instill in their children. Yoder, 406 U. S., at 218.
Like the compulsory high school education considered in Yoder, these books impose upon children a set of values and beliefs that are “hostile” to their parents’ religious beliefs. Id., at 211.
And the books exert upon children a psychological “pressure to conform” to their specific viewpoints. Ibid. The books therefore present the same kind of “objective danger to the free exercise of religion” that we identified in Yoder. Id., at 218.
That “objective danger” is only exacerbated by the fact that the books will be presented to young children by authority figures in elementary school classrooms.
The Context:
Subverting parents and bypassing state law
As researcher and writer Sheena Rodriguez previously reported for Live Action News (emphasis added), Planned Parenthood and its partners in the Future of Sex Ed Coalition fully intended the integration of such controversial materials into school classrooms — and not just in sex education class (emphases added):
In 2015, Planned Parenthood ramped up its intentions to include more ‘LGBT-inclusive’ content in its youth sex-ed programs, citing the growing number of children identifying as LGBT+ as the reason…. But to fully implement this agenda… Planned Parenthood and its associates would need more than sex-ed curriculum.
The [Future of Sex Ed Coalition]’s collaboration with the ALA [American Library Association] allows the coalition to target youth, subvert parents, and bypass state restrictions on sex-ed programs by ensuring that certain sexually explicit and controversial material is placed in public schools and local libraries.
→ This attempt to “subvert parents” and “bypass” the law was at the heart of the lawsuit brought against the Maryland board of education.
The American Library Association recommends entire book lists to schools, and even awards some books (including one lauding the work of “abortion doulas”). Planned Parenthood’s partnership with the ALA is helping to indoctrinate youth in schools, as the ALA is part of the National Coalition Against Censorship (NCAC), “which also includes Planned Parenthood Federation of America,” noted Rodriguez.
Parents as ‘pariahs’
Rodriguez added:
Each of the groups in the NCAC and FoSE coalitions has advocacy arms actively working against parents who are fighting to keep Planned Parenthood-backed sex-ed programs and sexually graphic books from being easily accessed by children.
The ALA characterizes parental resistance to allowing children easy access to such materials as “false claims of illegal obscenity for minors” as well as objections to “inclusion of LGBTQIA+ characters or themes; and inclusion of topics on race, racism, equity, and social justice.”…
Oral arguments in [Mahmoud v. Taylor] were heard at the U.S. Supreme Court on Tuesday, April 22, 2025….
During the oral arguments, Eric Baxter, the attorney representing the parents in the case, alleged that Board of Education openly chose “indoctrinating” books — which were integrated into other standard daily instruction outside of sex-education — to “disrupt cis-normativity [and] disrupt hetero-normativity” without parental notification once the Board decided that “every student would be taught from inclusivity storybooks.”
Planned Parenthood and its coalition partners have fully intended to “subvert parents” and “bypass” the laws, as Rodriguez noted. Given the fact that the American Library Association collaborates with the Future of Sex Education coalition (Planned Parenthood and others), it seems highly plausible that some of these “inclusivity” storybooks were part of the ALA’s recommended book list for school libraries.
And Justice Neil Gorsuch, during oral arguments, pointed out that even the courts recognized these books as attempt to influence young minds:
As noted by Justice Neil Gorsuch, a district court found that the LGBTQ+ curriculum’s use outside of sex-ed purposes for pre-school and elementary school students was done for the purposes of influencing the students’ ideology — a point conceded by Montgomery County Public Schools attorney Alan Schoenfeld.
According to the Becket video below, those parents were made to feel like “pariahs” for objecting:
Not just one county, not just one state
On April 9, Maryland Attorney General Anthony G. Brown along with the AGs of 19 other U.S. states filed an amicus brief at SCOTUS to defend the Montgomery County Board of Education’s actions. The AGs argued:
… the use of curricula with LGBTQ-inclusive books without an opt-out option falls within public schools’ longstanding authority to foster safe learning environments and does not violate anyone’s right to free religious exercise.
Although the case focuses on policies of the Montgomery County Board of Education, it could be consequential for public schools nationwide.
Given the fact that “a number of states across the nation follow the National Sexuality Education Standards (NSES) or similar objectives” which “also utilize ‘inclusive‘ language tailored to LGBTQ student populations” — as reported by Live Action News — then Mahmoud v. Taylor could definitely be consequential nationwide.
The AG’s press release went on to note that the storybooks were intended to “foster inclusivity” because “LGBTQ students experience disproportionate levels of harm from discrimination and bullying in schools,” adding that “the books in question are not sex-education, but are designed to foster tolerance and respect for LGBTQ individuals.”
Read pages 22-27 of the SCOTUS decision to see descriptions of some of the books and curriculum instruction in question. Alito notes:
Like many books targeted at young children, the books are unmistakably normative. They are clearly designed to present certain values and beliefs as things to be celebrated and certain contrary values and beliefs as things to be rejected.
The 19 state AGs claim that the books “are not sex-education,” because they aren’t being taught as sex education — but the books are absolutely teaching specific values surrounding sexuality and gender, right in line with Planned Parenthood (and its coalition partners’) agenda.
Commentary:
The example of Montgomery County appears to be a textbook case of Planned Parenthood’s vision for making an end-run around parental values (and even the law) in an attempt to indoctrinate children far earlier than when a typical sex education class would normally take place. This, coupled with Planned Parenthood’s pro-abortion agenda promoted to students, seeks to erode trust between parents and their children, positioning Planned Parenthood as the sole authority for all things abortion, gender, and sexuality — all while the corporation makes money from abortion and “gender-affirming” care.
Liberty Counsel founder and chairman Mat Staver said in response to the court’s opinion, “The First Amendment simply does not allow government schools to require families to sacrifice their religious beliefs for their children to attend school.”
He added, “Parents in all states should be given adequate opportunity to review any instructional material and must be given the ability to opt their children out of instruction that violates their faith.”
The Bottom Line:
While Mahmoud v. Taylor is a win for parental rights, national sex education standards across the country are applied in different ways. Parents must be vigilant to ask questions, request to review all materials that are being used to instruct their children in schools, and demand answers and accountability when they encounter roadblocks.
Planned Parenthood is not a friend to parents, and it has long been known that the corporation seeks to subvert their authority in their children’s lives when it comes to abortion and gender-ideology. This isn’t done merely through sex education classes; Planned Parenthood’s ideology is now being woven into general classroom instruction under the noses of many unsuspecting parents.
Sending a child to public or private school should never negate a parent’s right to direct the religious upbringing of his or her child.
