Little v. Llano County Legalized Library Censorship. What Exactly Does This Mean?: Book Censorship News, February 13, 2026

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.

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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.  

• Caste, the Origins of our Discontents by Isabel Wilkerson
• It’s Perfectly Normal:  Changing Bodies, Growing Up, Sex, and Sexual Health by Robie Harris
• In The Night Kitchen by Maurice Sendak
• My Butt Is So Noisy!, I Broke My Butt!, and I Need A New Butt! by Dawn McMillan 
• Larry the Farting Leprechaun, Gary the Goose and His Gas on the Loose, Freddie the Farting Snowman, and Harvey the Heart Has Too Many Farts by Jane Bexley
• Shine by Lauren Myracle
• They Called Themselves the K.K.K.:  The Birth of an American Terrorist Group by Susan Campbell Bartoletti
• Being Jazz:  My Life as a (Transgender) Teen by Jazz Jennings
• Spinning by Tillie Walden
• Gabi, a Girl in Pieces by Isabel Quintero
• Under the Moon:  A Catwoman Tale by Lauren Myracle
• Freakboy by Kristin Elizabeth Clark  

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.  

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Book Censorship News: February 13, 2026

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.

• In her ongoing court battle, Amanda Jones has prevailed in the Louisiana State Supreme Court against Michael Lunsford and Citizens for a New Louisiana. Now she can continue her case and she’s owed 4 years of court fees from Lunsford.
• There’s a new Freedom to Read bill being floated in Alaska.
• Maya Angelou’s estate has joined in the lawsuit filed over Utah’s state-sanctioned book banning.
• This is a fantastic piece in one of South Carolina’s major newspapers about how conservative state gubernatorial candidates are using public libraries as a tool in their campaigns, rather than focusing on actual, real issues in the state.
• Lapeer Community School Board of Education (MI) removed 59 books from school shelves following complaints by a handful of parents. You may think this community sounds familiar, and that’s because they dealt with this at the public library. Now it’s at the schools. Books banned are on the themes the far right has been targeting since the beginning. It doesn’t sound like they followed any process except to bow to a few loud voices. An update later this week revealed that it’s actually over 80 books.
• “Rep. Chris Banning, R-Bixby, said he filed HB 2978 to remove books “that completely disgrace women that we can’t read out loud.” The bill passed by a vote of 10-1.” This is in Oklahoma and aims to ban even more books from school libraries. May there be no doubt, but this’ll be used not only for the usual targets, but it’ll be used to remove romance books, too.
• The Alabama governor’s race is becoming more and more interesting, as the democratic candidate brought up the absurdity of book bans and library censorship in the state. The chair of the Alabama Public Library Services–which has banned trans books in public libraries and withheld state funds to libraries which don’t bow to their banning demands–isn’t happy. That chair is also the former chair of the state republican party and a candidate for lieutenant governor.
• Scottish libraries are seeing a rise in LGBTQ+ book complaints. Librarians are already speaking up about the chilling effect this will have. It’s almost like they’ve seen this happening in the US.
• Columbia High School (NJ) removed The Brief Wondrous Life of Oscar Wao by Junot Diaz from the AP Literature curriculum this year, after it’d been used for several years. Why? The need to protect students from challenging themes presented in it. Students have protested the decision.
• ProPublica further exposes how the Institute of Museum and Library Services has become a tool of the regime, rather than a government agency for public libraries and museums.
• Despite no academic credentials in history or the constitution, a christian nationalist is one of those behind a bill in Utah to dramatically change K-12 civics education.
• Residents in Randolph County, North Carolina, silently protested the county board’s decision to disband the library board for not removing an LGBTQ+ book.
• Pine-Richland School Board (PA) is suspending its controversial book ban policy, though there are still several books under review.
• Cy-Fair Independent School District (TX) has returned the chapters that were banned from science textbooks back into the books. When partisan board members lose their seats on school boards because people want their kids educated, not indoctrinated, things go back to the way they should be.
• “An Iowa man asked the Mahaska County Board of Supervisors at its recent meeting to reduce funding to the Oskaloosa Public Library due to several books he found objectionable.” One dude didn’t like that gay people exist, let alone write books. That’s the real headline–no funding was revoked.
• The bill which would outlaw collaborations between public schools and public libraries advanced in Iowa. Here’s why that kind of bill undercuts education.
• This is a thought-provoking read about Hachette fighting book bans while publishing Justice Alito, who is pro-censorship. I think a lot of the points made here are good. I also think it continues to misconstrue Mahmoud v. Taylor as a book banning bill when it is not–it’s a religious liberty bill. That distinction matters because it means that parents in Texas whose kids are going to be forced a Bible-infused curriculum can demand their kids be removed from those lessons. I do think it would be hypocritical of a publisher to not publish someone based on their beliefs, too–just as it would be hypocritical of libraries where there’s interest in an Alito book not to purchase it for their collections. That piece said, the lack of accountability for powerful people like Alito is the real issue at play here, and yes, Hachette’s acquisition of his book is a reminder of their being a business and not a charity.
• Cook County, Illinois, is late in distributing its property taxes to appropriate parties, and it’s meant a lot of problems for Chicago-area public libraries.
• Redlands Unified School District (CA) wants to now give the principal at district schools the power to approve books purchased for the library, including a record of which library worker selected it so that parents can personally harass them. This is a state with an anti-book ban law; in Redlands, it’s not being enforced, so the radical board keeps taking more rights away from its students.
• Where and how Toronto, Canada, area libraries are fighting back against censorship of LGBTQ+ books.
• Competing bills about library books in New Mexico–some that would protect against book bans and one that would allow bans to happen really freely–may make no forward progress this legislative session.
• New Hampshire senators are obsessed with passing a law to ban books in the state, despite the fact this very legislative proposal last year was vetoed by the governor.
• More on the Utah legislative proposal to not only further ban books in the state, but add to the list of “sensitive materials” that could be challenged in schools to items in classroom libraries, digital materials, textbooks, and more.
• In Alabama, the bill that would allow easy removal of public library board members has advanced. In other words, if the library board doesn’t behave local politicians want them to, they can simply be removed by those politicians. It removes local control and authority over libraries and cedes it to partisan politics.
• PEN America hosted an event at Texas A&M University over the censorship happening on that campus as well as other campuses across the state.
• Last week, we learned that an educator who was fired for reading a humorous book about butts to a classroom was unjustly fired. Now, the school is appealing that decision. This case has been dragging on for years.
• Florida’s House has passed their new book banning bill, HB 1119, which undermines the Miller Test and forces decisions on whether or not to remove a book based on isolated passages (rather than the text as a whole). The House also passed HB 31, which bans books which reference the West Bank. Don’t write Florida off. This is a blueprint of what happens elsewhere.
• Sumner County Libraries (TN) are considering what to do with 50 books identified as possible for removal under directive from the Tennessee Secretary of State. “The titles span a wide range — from books about pronouns and self-identity to all-inclusive churches, stories from children in the Holocaust and even a book debunking myths on outbreaks like COVID-19.”
• The Hill gave space to two library conspiratorial cranks last week. This week, it’s given over to the director of The Librarians to talk about why and how defending the right to read is downright American.
• “On Tuesday night, over a dozen Livingston Parish [LA] residents, ranging from local pastors, teachers and library alliance members, debated whether the 2014 graphic novel “This One Summer” by Mariko Tamaki and Jillian Tamaki should remain in the teen section of the parish library.” Some folks in Livingston Parish are mad about a teen book in the teen area.