The 4th Circuit Court of Appeals strongly criticized a federal district judge who refused to issue a preliminary injunction in a case involving a public elementary school graduation ceremony held at a Christian college that included prayer.
The case involves an elementary school in Greenville, South Carolina, which scheduled its graduation ceremony in the chapel of a local Christian college and included a prayer as part of the ceremony. A student and her parents filed a lawsuit and asked for an injunction barring the ceremony from taking place as planned until the full case could be heard. They also asked to be allowed to continue the case under pseudonyms so they wouldn’t have to face harassment and potential violence.
After the judge ruled against both of those motions without bothering to even issue a written ruling on the merits of them, the family appealed and asked that the judge be removed from the case. The 4th Circuit Court of Appeals ruled that the judge ignored the Federal Rules of Civil Procedure, which require a written ruling spelling out the findings and conclusions of law, didn’t even bother to analyze the legal merits of the case and removed him from the case.
In denying Plaintiffs’ motion for a preliminary injunction, the district court provided no analysis of the law and made no attempt to apply the four factors mentioned above to the facts as alleged in the complaint. Thus, we are constrained to remand the case for reconsideration of the issue. We likewise conclude that in denying the unopposed motion to proceed pseudonymously, the district court erred for the same reason stated above. Accordingly, we vacate the denial of Plaintiffs’ motions for a preliminary injunction and to proceed pseudonymously and remand for reconsideration and for the opportunity for the district court to provide an analysis supporting any subsequent rulings.
Finally, we agree with Plaintiffs that the case be reassigned to a different district judge on remand and so order.
The judge who has been removed said during the hearing on those motions that the family was “making a mountain out of a mole hill.” That isn’t a legal conclusion at all, it’s a sneer. The family will now argue for those motions before a different judge, who will have to actually consider the merits and issue a ruling.