Does the Montgomery County Board of Education's introduction of “LGBTQ+-inclusive” storybooks into the K-5 curriculum, combined with its decision to rescind parental opt-out policies, unconstitutionally burden parents' right to the free exercise of religion? Specifically, does this policy substantially interfere with the religious development of children in a manner that creates an objective danger to the free exercise of religion? If so, is the Board's no-opt-out policy narrowly tailored to serve a compelling state interest?

• The Board's no-opt-out policy infringes on parents' right to the free exercise of religion under the First Amendment.
• Parents possess a fundamental right "to direct the religious upbringing of their children," as recognized in *Wisconsin v. Yoder*.
• The mandated instruction poses "a very real threat of undermining" the sincere religious beliefs and practices parents wish to instill in their children.
• Forcing young, impressionable children to engage with normative materials that contradict their faith constitutes a substantial burden on religious exercise.

• The curriculum provides mere “exposure to objectionable ideas” or lessons in “mutual respect,” rather than coercive indoctrination.
• Under *Bowen v. Roy* and *Lyng v. Northwest Indian Cemetery Protective Assn.*, the Free Exercise Clause does not require the government to conduct internal affairs in ways that comport with specific religious beliefs.
• The decision in *Wisconsin v. Yoder* is "sui generis" and tailored specifically to the unique facts of the Amish community rather than providing a general principle.
• Parents who object to public school curricula remain free to utilize private schools or home education as alternatives.

• The Court held that petitioners are entitled to a preliminary injunction because they are likely to succeed on the merits, will suffer irreparable harm, and the balance of equities and public interest favor them (*Winter v. Natural Resources Defense Council, Inc.*).
• Relying on *Wisconsin v. Yoder* and *Espinoza v. Montana Dept. of Revenue*, the Court affirmed that parents have a right to direct the "religious upbringing" of their children, which is violated by policies that "substantially interfere with the religious development" of children.
• The Court found the storybooks are "unmistakably normative," presenting specific views on same-sex marriage and gender identity as things to be celebrated while framing contrary views as "hurtful," thereby creating an "objective danger" and psychological "pressure to conform" similar to that in *Yoder*.
• The Court rejected the Board's reliance on *Bowen v. Roy* and *Lyng v. Northwest Indian Cemetery Protective Assn.*, ruling that public school instruction involves direct, coercive interactions with children rather than mere "internal affairs."
• Because the burden is of the same character as in *Yoder*, the Court applied strict scrutiny regardless of whether the policy was neutral or generally applicable (*Employment Div., Dept. of Human Resources of Ore. v. Smith*).
• Under strict scrutiny, the government must demonstrate that its policy advances "interests of the highest order" and is "narrowly tailored" to achieve those interests (*Fulton v. Philadelphia*; *Church of Lukumi Babalu Aye, Inc. v. Hialeah*).
• While the Board's interest in an undisrupted school session is compelling (*Grayned v. City of Rockford*), the no-opt-out policy is not narrowly tailored because the Board continues to permit opt outs for other activities and the "Family Life and Human Sexuality" unit under Maryland law (Code of Md. Regs., tit. 13A, § 04.18.01(D)(2)).
• The Court concluded that the loss of First Amendment freedoms constitutes irreparable injury (*Roman Catholic Diocese of Brooklyn v. Cuomo*).