Reverses Denial of Preliminary Injunction Sought by Temecula Students and Teachers
SANTA ANA, CA, May 20, 2025—A California appellate court yesterday handed down a landmark ruling affirming the right of teachers to teach—and students to learn—about concepts that conflict with school board members’ ideological positions. The Court of Appeal reversed a lower court’s denial of students and teachers’ request for a preliminary injunction preventing the Temecula Valley Unified School District Board of Trustees (“Board”) from enforcing its sweeping ban on an ill-defined range of content vaguely labeled “Critical Race Theory and other similar frameworks.” The decision striking down the Temecula curriculum ban is the first in the nation from a state court applying a state constitution to block an anti-CRT policy.
The unanimous ruling by the three-justice appellate panel ordered the Board to stop enforcing its policy while the case proceeds, finding it to be unconstitutionally vague and “seemingly irreconcilable” with state-mandated educational standards. The Court emphasized that the policy’s vague provisions chilled instruction on fundamental concepts such as slavery, Jim Crow laws, the Civil Rights movement, and “still-prevalent contemporary racial issues.”
In a 38-page opinion, the Court of Appeal condemned the policy as “ambiguous,” “unclear in scope,” and lacking both “definitions” and “enforcement guidelines.” The Court explained that under the policy, teachers were “left to self-censor and potentially overcorrect, depriving the students of a fully informed education and further exacerbating the teachers’ discomfort in the classroom. Rather than lead the classroom and moderate healthy discussion, the teachers [were] forced to leave children’s questions unanswered or potentially let a classroom conversation about race devolve out of fear that their intervention would trigger a… violation.” The Court’s decision frees Temecula Valley educators from the ideologically-driven restrictions that the Board’s policy imposed.
“This decision is a beacon of hope for educators and students across California,” said Dawn Sibby, teacher at Temecula Valley High School. “If we are ever to become a democracy free from discrimination, our students must learn the true history of our nation and confront the real discrimination that people of color, women, and LGBTQ+ people have endured and continue to endure.”
Since its enactment in late 2022, the policy has chilled Temecula teachers, who have struggled to teach State-mandated curriculum while also attempting to follow the Board’s new and impossibly unclear rules. The policy drove teachers at a Temecula middle school—with the exception of plaintiff Katrina Miles, the school’s sole Black educator—to stop teaching Roll of Thunder, Hear My Cry, a Newbery Award-winning novel about a Black family’s struggle against racism in 1930s Mississippi. It left teachers at a loss as to how to teach standards-mandated history topics—including debates over the expansion of slavery and anti-Asian exclusion movements—without discussing racial oppression. And it has placed Temecula students at a marked disadvantage relative to their peers across the State.
“Today’s ruling is a bellwether for California school officials seeking to censor students’ access to a fact-based education,” said Amanda Mangaser Savage, Strategic Litigation Counsel at Public Counsel. “As the federal government escalates its attacks on public schools, the decision makes plain that California courts will not tolerate school officials’ attempts to impose their ideological positions on teachers and schoolchildren. As the court recognized, the purpose of public education is to prepare all students for meaningful civic education—an impossible objective if those students are forbidden from learning about past and current injustices. Ignorance of the truth cannot be the means or end of public education.”
The students and teachers’ challenge to the resolution has received broad backing from public officials and organizations, including California Attorney General Rob Bonta, the California Teachers Association, PEN America, and Penguin Random House, all of whom filed briefs supporting plaintiffs’ request to enjoin the Board’s curriculum censorship.
“With this case, we’re not just fighting for the young people of Temecula but for all students across California,” said Elizabeth Schilken, an attorney at Ballard Spahr. “This vaguely worded resolution suppressed discussion on a wide range of topics involving racism and discrimination, making educators afraid to teach honest history. This injunction sends a clear message that students have a constitutional right to receive information about history and current events, and schools must not censor or distort that truth.”
The Temecula students, parents, and educators—along with the educators’ union, the Temecula Valley Educators Association—are represented by Public Counsel and Ballard Spahr LLP. Ballard Spahr is working on the case as part of the firm’s Racial Justice and Equality Initiative, a pro bono plan of action dedicated to combating racial injustice and inequity through litigation.
Read the Court’s opinion here.
The case is Mae v. Komrosky. More information on the case, the legal documents, and the full expert declarations in support of the requested injunction are available at temecularighttolearn.org.
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