Info
Leila Green Little was the lead plaintiff in Little v. Llano County, a court case that has had and will continue to have significant bearing on the kinds of materials that public libraries offer their patrons. In an en banc decision out of the Fifth Circuit last May, the ruling was that government officials have the ultimate say in public library collections in Mississippi, Louisiana, and Texas. It was the first loss for the plaintiffs, who appealed the case to the Supreme Court. The Court ultimately decided not to take it up.
But what does the ruling in this case actually mean? What have people with a vested interest in library censorship decided that it means? Those are just two of the questions that continue to emerge as we move forward with the ruling from the Fifth Circuit. Little v. Llano County has already been cited numerous times as proof that the government can decide what people do and do not have access to in public libraries. One such citation–and one worth watching–is Florida’s government in their current appeal of a lawsuit to the 11th Circuit. Last summer, a judge ruled that no, the books that the state insisted were “obscene” and needed to be removed from school library shelves did not, in fact, rise to that definition. The state has leaned heavily into the Little v. Llano County ruling in their defense.
Little v. Llano County will continue to have an impact on library materials decisions and your right to access books in your public libraries. Today, lead plaintiff Leila Green Little is here to share the impetus for the lawsuit when the case began, how it progressed through the judicial system, and what the immediate and future impact of the Fifth Circuit’s ruling will be for public libraries nationwide.
**
Four years ago, a storm of censorship in public libraries began brewing in Llano, Texas, and a lawsuit ensued. The case bearing my name, Leila Green Little, et al., vs. Llano County, et al., essentially reached its conclusion on December 8, 2025 when the Supreme Court of the United States declined to hear it. This means the en banc ruling of the Fifth Circuit Court of Appeals stands. But what does this all really mean for public librarians, patrons, and local elected officials?
Please note that I’m a library patron with a master’s degree in library science, an advocate for intellectual freedom, and a plaintiff in this lawsuit. I am neither a lawyer nor a legal scholar. But I offer you my perspective here.
What was this case about?
In the fall of 2021, Llano County officials instructed the public library director to remove books from the library after hearing from citizens about books that offended them. Our lawsuit alleged censorship of these 17 specific titles.
Many other things occurred with this library over the past four years, including the termination of OverDrive access, reconstitution of a library advisory board, closure of that board’s meetings to the public, consideration of closing the library completely, and the firing of head librarian Suzette Baker. Baker filed a lawsuit of her own, and eventually received a $225,000.00 settlement from Llano County.
What did the courts say?
We plaintiffs received favorable rulings from the federal district court and the original panel of the Fifth Circuit Court of Appeals. The federal district court issued a preliminary injunction ruling that required the books to be put back on the shelves and into the library’s online catalog in March 2023. The Fifth Circuit Court of Appeals’ panel of 3 judges partially upheld that injunction. A circuit court judge requested an en banc hearing, meaning that the entire roster of judges from the Fifth Circuit would hear our case. The en banc ruling was issued in May 2025, and it is what will remain in effect in the three states within the circuit: Texas, Mississippi, and Louisiana. A majority of the judges agreed to overturn the precedent that the Fifth Circuit itself created decades prior in Campbell v. St. Tammany’s Parrish School Board.
A majority of judges decided that public library patrons do not have a first amendment right to access information in their public libraries. Therefore, censorship is now legal in the public libraries that serve the 38 million Americans who live in three states. It is important to note, however, that Llano County’s claim that library books constitute government speech was rejected by a majority of judges, and therefore does not apply here.
Board of Education, Island Trees Union Free School District No. 26 v. Pico by Pico, commonly known as the Pico case, has not been overturned at the Supreme Court level, and my case does not change that. It remains in effect.
What does this ruling mean for library patrons, librarians, and local elected officials?
This ruling is devastating for those of us who value our libraries as public spaces of free inquiry that stimulate intellectual curiosity across the lifespan. This ruling in fact gives local elected officials that govern public libraries the ability to control their collections however they so choose. Prior to this ruling, content and viewpoint-based discrimination of library books was prohibited, so a librarian and/or elected official couldn’t just censor books. Now they can.
Local advocacy is more important than ever, and so is voting for candidates who value intellectual freedom. Government officials now ultimately determine what is on the shelves of public libraries, and therefore our books are on the ballot every time we go vote.
Librarians who do not comply with orders/instructions from their elected officials now risk termination and a lack of redress.
Library patrons will be rewarded with a library that reflects their needs only if their local officials agree with them and allow a library to look like they want it to. If you happen to be a close-minded prude who lives in a rural area with an anti-library commissioners’ court, you might be happy about this. If you’re a library patron who wants access to a wide variety of information in that same rural area, you understand how dangerous this ruling is.
In short: this is a nightmare for our public libraries. They will become cudgels, vulnerable to the inevitable sea change of political powers. They may become political, religious, and/or sociocultural propaganda centers, funded by local tax dollars. Or they may remain the same. “Local control” portends ominous things for a great many library patrons, though.
Here in Texas we’ve seen changes in the recommendations of the Texas Association of School Boards (TASB Localized Policy Manual Update 126) that directly cite our case. We know of many examples, whispered to us for fear of public scrutiny, of public libraries removing books to placate citizens and elected officials who are citing our case.
Anyone who celebrates this ruling has clearly not read enough stories about absolute power corrupting absolutely. There is of course a logical endpoint to censorship, and we will see it sooner rather than later. Censorship is inevitable when malleable politicians, and not professional librarians governed by standards and practices, control our reading materials. We will see it sooner rather than later.
How is this case affecting others?
Little v. Llano County’s en banc opinion has been cited in 13 other cases so far across the country, and been written up in numerous articles and law review papers. Both sides are wielding this opinion to shape their arguments for and against censorship, with legal briefs citing it coming from such disparate sources as America First Legal (who benefitted financially from publicity and fundraising off our case) and book publishers and a state chapter of the NAACP. Our case was cited in the filings for the Crookshanks, et al., v. Elizabeth School District case, in which the appeal on the preliminary injunction was recently dismissed by the defendants.
I’m thankful to see that the egregious majority opinion that stands in Little v. Llano is being used to combat censorship in other legal/judicial arenas, and I hope it adds to the deluge of water that will inevitably break this dam of suppression of the written word.
Where’s the good news?
Despite pro-censorship activists citing our case as a reason to exclude books wholesale from public libraries, local citizens have power to change what happens. In Mat-Su Burough District in Alaska, an Assemblyman proposed an ordinance that would have eliminated all materials from the public library that contained sex—including in the adult section or available through interlibrary loan. This ordinance directly referenced our case, citing, “Just as the authorities did in Llano County TX, the Matanuska-Susitna Borough Assembly is likewise directing how the Matnuska-Susitna Borough chooses to spend public dollars for materials in public buildings which are staffed and maintained with public monies.” After community members spoke up in opposition of the ordinance, it was withdrawn. This is a victory for the patrons of that library system, and it should embolden advocates for libraries to raise their voices anytime censorship is threatened.
In our case’s en banc opinion, the majority concurred that recourse for disagreement with local censorship is the ability for the public to shape local policies at the ballot box. The Court wrote, “They [people] can speak out against (and vote against) policies and officials they disagree with.” This is more true now than ever, and it now remains one of our only real powers for recourse. Support of intellectual freedom and rejection of censorship should become “kitchen table issues” and decisions that guide voting choices as much as reproductive health and immigration. Citizens ultimately do have all the power here. We just have to wield it and determine what our public libraries will become. We have seen recent victories in elections, with citizens wising up to politicians who use fear of books to win votes and choosing an alternative candidate. We need more of this. And every library patron in America needs to understand that their first amendment rights are just as fragile as those of us in Texas.
As my attorney Katherine Chiarello has said, “Our constitutional rights are not self-actualizing.” We have to fight for them, or yours may be taken away like mine and my children’s.
Leila Green Little is a rural mom and intellectual freedom advocate. She began fighting against censorship in her local public library system in 2021. In 2022, she and six others sued their county (Leila Green Little, et. al, v. Llano County, et. al) for banning books. Unfortunately, the end result of this case is that the Fifth Circuit Court of Appeals overturned decades of precedent and ruled that public library patrons do not have a first amendment right to access information. She continues to advocate for the freedom of access in both public and public school libraries in multiple arenas. Leila earned a master’s degree in library science from the University of North Texas, and a master’s degree from Texas Tech University Health Sciences Center in speech-language pathology. She’s been happily married for over 20 years, loves to read banned books, travel, and watch classic movies.
**
This week’s top-line story: the CIA has ended its World Factbook, a vital reference tool used to verify factual information about countries across the globe. It’s used by everyone from young school children to adults seeking basic information about places around the world. This shutdown came with no warning or explanation; we can likely guess as to why it was removed, given the priorities of the current regime, including the overthrow of facts and information in favor of partisan propaganda. You’re able to access the World Factbook, but it is from 2020. This means a lot of really important information is out of date.