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Health Freedom Defense Fund, Inc., a Wyoming Not-for-Profit Corporation, et al. v. Alberto Carvalho, in His Official Capacity as Superintendent of the Los Angeles United School District, et al.

Paid petition · United States Court of Appeals for the Ninth Circuit, No. 22-55908 · judgment July 31, 2025


Certiorari denied · May 18, 2026
Pre-decision estimate: 2% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

  1. Does this Court’s opinion in Jacobson v. Commonwealth of Massachusetts, 197 U.S. 11 (1905), limit a court’s review of government mandated medical treatments to the highly deferential rational basis review or does Jacobson require heightened scrutiny based on a balancing test, as the Court held in Cruzan v. Director of Missouri Department of Health, 497 U.S. 261 (1990)?

  2. If, as the Ninth Circuit held, Jacobson limits courts to rational basis review, should it be overruled or limited to its specific facts because it is inconsistent with modern constitutional scrutiny, including this Court’s opinions in Cruzan and Sell v. United States, 539 U.S. 166 (2003), which explicitly recognized a person’s fundamental interest in rejecting unwanted medical treatments? (i)

Counsel of record

For petitioner
Scott James Street
JW Howard Attorneys, Ltd.

For respondent
Amelia Anne McDermott
Littler Mendelson, P.C.

Case

Conference history
Distributed for 2 conferences

Amicus briefs
2 cert-stage

Linked docket
25A431

Proceedings

  1. May 18 2026
    Petition DENIED.
  2. Apr 22 2026
    DISTRIBUTED for Conference of 5/14/2026.
  3. Apr 17 2026
    Reply of petitioners Health Freedom Defense Fund Inc., et al. filed.
  4. Apr 08 2026
    Brief of respondents Alberto Carvalho, et al. in opposition filed.
  5. Feb 11 2026
    Motion to extend the time to file a response is granted and the time is extended to and including April 8, 2026.
  6. Feb 10 2026
    Motion to extend the time to file a response from March 9, 2026 to April 8, 2026, submitted to The Clerk.
  7. Feb 05 2026
    Response Requested. (Due March 9, 2026)
  8. Jan 29 2026
    Brief amicus curiae of New Civil Liberties Alliance filed.
  9. Jan 29 2026
    Brief amici curiae of Texas, et al. filed. (Distributed)
  10. Jan 28 2026
    DISTRIBUTED for Conference of 2/20/2026.
  11. Jan 21 2026
    Waiver of right of respondent Alberto Carvalho, et al. to respond filed.
  12. Dec 23 2025
    Petition for a writ of certiorari filed. (Response due January 29, 2026)
  13. Oct 15 2025
    Application (25A431) granted by Justice Kagan extending the time to file until December 28, 2025.
  14. Oct 13 2025
    Application (25A431) to extend the time to file a petition for a writ of certiorari from October 29, 2025 to December 28, 2025, submitted to Justice Kagan.