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A mixed victory for Christian parents over educators in contentious MI case

Mead v. Rockford Public School District is part of ongoing conflicts over pronoun use and educators’ enabling their children to pursue “social and gender transition” in schools without their knowledge or approval.

(Image: null / Shutterstock)

On September 18, 2025, a federal trial court judge in Michigan allowed a parental claim to proceed against educators who followed a board policy under which they “actively concealed” their actions in changing the gender identification of their seventh-grade daughter by referring to her using a male name and pronouns.

The “educators” essentially allowed this traumatized and confused student, called “G.M.”, to pursue steps on the road to identifying as “transgender”.

Mead v. Rockford Public School District is largely a win for parents in the ongoing conflicts over pronoun use and educators’ enabling their children to pursue “social and gender transition” in schools without their knowledge or approval. Mead is noteworthy because it created a split in the federal courts over educators’ intrusions into parental rights in light of Foote v. Ludlow School Committee, a case that I discussed earlier in Catholic World Report, wherein the First Circuit allowed Massachusetts educators to withhold similar information from parents.

Consequently, litigation is likely to reach the Supreme Court over the fundamental right of parents to have educators not interfere with their right to direct the education and upbringing of their young by informing them about what their children with gender dysphoria are doing in school.

Background of Mead v. Rockford Public School District

G.M. attended East Rockford Public Schools from kindergarten through eighth grade.

As a sixth grader in 2020, while undergoing academic and mental health difficulties, educators granted G.M.’s mother’s request to provide her with counseling. As G.M.’s mental state worsened in 2021, upon starting seventh grade, her parents sent her to a psychologist who diagnosed her with Autism Spectrum Disorder, Generalized Anxiety Disorder, and Major Depressive Disorder.

Nearing the end of seventh grade in May 2022, G.M. sent her counselor a note asking that she be referred to by a masculine name; consistent with board policy, the counselor and staff agreed to G.M.’s request without informing her parents.

When G.M. began eighth grade, school staff—without her parents’ knowledge or approval—again addressed G.M. using a male name and pronouns.

Discovering what the court described as officials’ deceit, the Meads withdrew G.M. from school effective October 24, 2022, choosing to homeschool their daughter.

Litigation

Represented by Alliance Defending Freedom, the Meads filed a lawsuit against the board on December 18, 2023, raising three claims.

The parents initially alleged that the board’s policy violated their First Amendment right to the free exercise of religion. The parents also charged that it violated their Fourteenth Amendment fundamental rights both to direct G.M.’s upbringing, education, and healthcare as well as to procedural due process.

The court rejected the free exercise claim because the policy, which it described as neutral and generally applicable, did not compel students or their parents to believe, do anything, or require G.M. to use a different name or pronouns, nor did it refer to religion or religious conduct. The court upheld the policy as rationally related to what it described as the board’s legitimate interest of promoting a safe and supportive learning environment for LGBT students.

Turning to the substantive due process claim, citing three Supreme Court cases discussed below, the judge determined that officials “took affirmative steps to deceive the Meads,” because the “allegations show some amount of coercion or interference…implicat[ing their] right to make fundamental decisions for G.M.”

The court then reasoned that the policy violated the Meads’ rights to procedural due process because officials failed to inform them that G.M. asked to be treated as a male and “conducted a ‘psychosocial intervention’ to treat their child’s gender dysphoria and other mental health disorders” without their knowledge or consent. It is unclear whether the board will appeal.

Reflection and analysis

Although denying the Meads’ First Amendment religion charge, the judge allowed their Fourteenth Amendment rights claim to proceed, relying on three Supreme Court cases alluded to above, starting with 1923’s Meyer v. Nebraska. In that case, the Court upheld parental rights to have their children study German in grades lower than the ninth. The Court acknowledged the fundamental parental right to direct the education and upbringing of their children, absent a showing of harm that the state had the right to prevent.

The judge next quoted 1925’s Pierce v. Society of Sisters of the Holy Name of Jesus and Mary, perhaps the Supreme Court’s most significant case protecting parental rights to direct the upbringing of their children In Pierce, along with upholding the rights of non-public schools to operate, the Justices emphasized that “[t]he child is not the mere creature of the state; those who nurture him and direct his destiny have the right, coupled with the high duty, to recognize and prepare him for additional obligations.”

Finally, the judge highlighted Troxel v. Granville, a controversial case in 2000 from Washington over visitation rights. He referenced the Justices’ observation that “the interest of parents in the care, custody and control of their children—is perhaps the oldest of the fundamental liberty interests recognized by this Court.”

In light of clear, unequivocal Supreme Court precedent, it is mind-boggling that educators blatantly and completely ignored the Meads’ legitimate rights to direct the education and upbringing of their minor daughter, a clearly confused child undergoing a traumatic crisis.

To make matters worse, these officials went so far as to deceive the Meads in refusing to inform them about G.M.’s well-being. These educators, who completely disregarded the Meads’ rights, let alone G.M.’s need for parental care and guidance, these “educators,” were averse to placing the legitimate needs of children ahead of their ideological wishes to indoctrinate youngsters. Such educators should no longer be permitted to act unilaterally in facilitating “transitioning” by impressionable minors who likely do not fully understand what they are doing.

Of course, children with gender dysphoria, such as G.M., deserve psychological care, understanding, and love. However, the “educators” in East Rockford trammeled parental rights to direct the education and upbringing of their daughter when they “took affirmative steps to deceive the Meads about their actions to socially transition G.M., which removed any possibility of process before or during the deprivation of their liberty interest.” In the process, these educators may well have caused G.M. and her parents even greater pain and emotional confusion as they grappled with moving forward.

Sooner or later, disputes such as Meade will reach the Supreme Court. When a case of this nature does get to the Supreme Court, its precedent on parental rights strongly suggests that it will find in their favor on this contentious issue.

Most recently, for example, in this year’s Mahmoud v. Taylor, admittedly on a different, but related issue involving sexuality, the Supreme Court upheld the primacy of parental rights to excuse their kindergarten to fifth-grade children in Maryland from instruction using LGBTQ+-inclusive texts they likely did not even understand. In another notable example on a dissimilar topic, in 2022’s Carson v. Makin, the Justices ruled in favor of parents from Maine on the basis that denying them the opportunity to enroll their children in the faith-based schools of their choice under a program providing tuition assistance if their local boards did not operate their own secondary schools violated their First Amendment right to the free exercise of religion.


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About Charles J. Russo 71 Articles
Charles J. Russo, M.Div., J.D., Ed.D., Joseph Panzer Chair of Education in the School of Education and Health Sciences (SEHS), Director of SEHS’s Ph.D. Program in Educational Leadership, and Research Professor of Law in the School of Law at the University of Dayton, OH, specializes in issues involving education and the law with a special focus on religious freedom. He is also an Adjunct Professor at Notre Dame University of Australia School of Law, Sydney Campus. He can be reached at crusso1@udayton.edu. All views expressed herein are exclusively his own.

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