Mirabelli v. Bonta · ¶10

The Ninth Circuit also expressed doubts about the District Court's decision on the merits. On the free exercise issue, it relied on a not-precedential Sixth Circuit decision and brushed aside Mahmoud v. Taylor, 606 U. S. 522 (2025), as “a narrow decision focused on uniquely coercive `curricular requirements.' ” App. 10a–11a (citing Doe No. 1 v. Bethel Local School Dist. Bd. of Educ., 2025 WL 2453836, *7 (CA6, Aug. 26, 2025)). The Ninth Circuit expressed skepticism about the parents' and teachers' Fourteenth Amendment due process claim because it viewed those claims as seeking to expand the protection afforded by established precedent.

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