C.C., a student at a Madison Local School District high school, wore a t-shirt displaying the phrase “Let’s Go Brandon” on multiple occasions during the 2024–2025 school year. The phrase originated from a televised NASCAR event where a reporter, while covering a crowd chanting a vulgar slogan directed at President Biden, suggested the chant was “Let’s go Brandon,” referring to the winning driver. The phrase subsequently became widely understood as a coded political insult. C.C. had worn the shirt without issue the previous school year, but in November 2024, a teacher instructed him to cover it. He complied initially, buttoning up the flannel shirt he was wearing on top. Later in the day, C.C. removed the flannel shirt due to the warm classroom temperature, leading to a disciplinary referral. Over the following months, C.C. wore the shirt on at least two additional occasions and was again disciplined by school administrators, including being warned that continued violations would result in further consequences.
Richard P. Conrad Jr., filed suit on behalf of himself and his son, C.C., seeking a preliminary injunction to allow C.C. to participate in upcoming school trips to the Mansfield Reformatory and Cedar Point amusement park. Conrad alleged that the School’s disciplinary actions were a form of impermissible viewpoint discrimination, arguing that the phrase on the shirt constituted political speech protected under the First Amendment. He further asserted that C.C. suffered irreparable harm by being excluded from the trips and by the stigma associated with disciplinary sanctions.
The District defended its actions by emphasizing the educational environment and the need to maintain standards of civility and respect. It argued that the phrase “Let’s Go Brandon” was reasonably interpreted as a euphemism for profanity—specifically “F*** Joe Biden”—and thus fell within the District’s authority to prohibit vulgar or offensive expressions under its student code of conduct. The District also pointed to a similar case from the Western District of Michigan (D.A. v. Tri-County Area Schools), where students disciplined for wearing “Let’s Go Brandon” shirts lost on summary judgment. That court in that case had concluded that the school’s interpretation of the phrase as vulgar was reasonable and that its enforcement of dress code provisions was lawful.
Courts consider four factors when deciding whether to grant a preliminary injunction: (1) whether the movant has a strong likelihood of success on the merits; (2) whether there is a threat of irreparable harm to the movant; (3) whether others will suffer substantial harm as a result of the injunction, should it issue the injunction; and (4) whether the public interest will be served by the injunction.
Applying this test, the Court began by analyzing whether Conrad had shown a likelihood of success on the merits. Citing Supreme Court precedent, the Court acknowledged that students do not shed their First Amendment rights at the schoolhouse gate, but those rights are subject to limitations in the context of school policies designed to preserve order and promote respect. While the Court recognized that political speech is highly protected, it reiterated that schools may restrict expressions deemed vulgar, profane, or otherwise disruptive. The Court noted that C.C.’s father explicitly acknowledged the euphemistic meaning of the phrase in the complaint, which strengthened the School’s position that the shirt could reasonably be interpreted as offensive.
The Court held that Conrad also failed to meet the high burden of showing by clear and convincing evidence that he was likely to succeed on the merits. The Court reasoned that Conrad had not shown that the School’s interpretation of the shirt’s message was unreasonable or unconstitutional.
On the question of irreparable harm, the Conrad argued that C.C. was suffering constitutionally significant injury by being barred from the Cedar Point field trip. However, the Court found that missing a non-essential school trip was not an irreparable injury warranting extraordinary relief, particularly because participation in the trip was contingent on conduct and the submission of fees and permission slips. Conrad had not submitted either, and the Court noted that he had waited until the week before the trip to file for injunctive relief, despite having been on notice since March that C.C. would be ineligible.
The Court also addressed the balance of harms and public interest factors. While it acknowledged the general public interest in protecting constitutional rights, it also recognized the importance of school authority to enforce disciplinary standards and maintain a respectful learning environment. The Court concluded that these considerations were essentially equal and did not favor granting an injunction.
Ultimately, the Court denied the motion for preliminary injunction.
Conrad v. Madison Loc. Sch. Dist. Bd. of Educ. (N.D. Ohio May 12, 2025) 2025 U.S. Dist. LEXIS 90494.
Note: High school students at private schools in California have certain free speech rights. That said, this decision reinforces that while schools must respect students’ rights to expression, they retain discretion to regulate speech that may reasonably be construed as vulgar or disruptive.