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CASE NAME
Henderson et al v. School District of Springfield R-12 et al
Overview
Plaintiffs, white employees of the school district, argued that their First Amendment rights were violated when they were required to attend a district-wide DEI training. The Eighth Circuit agreed with the district court in dismissing this claim, finding no violation of the Plaintiffs' rights.
Details
The district court granted in favor of the school district, concluding that Plaintiffs lacked because they had not been punished for expressing opinions that differed from the training and failed to demonstrate that their fear of punishment for sharing opposing views was anything more than speculative.
On , the school district argued both that Plaintiffs lacked standing and that no free-speech violation occurred because Plaintiffs were not required to endorse the content of the training and were not fired, demoted, transferred, or disciplined for voicing objections to it.
The Eight Circuit agreed with the district court and the school district, noting that Plaintiffs were paid for the training, received continuing education credit, and suffered no plausible penalties associated with the training. Plaintiffs’ fear of punishment for answering training questions incorrectly was not concrete enough to be considered an actual harm under the First Amendment. The court ruled that the school district had a right to instruct and advise employees on its policies through this type of training.
On November 27, 2024, the Eighth Circuit granted a petition to rehear the case "en banc," meaning that the full bench of the court would hear the case.
On December 30, 2025, the court reversed, vacated, and remanded the judgment of the district court. On rehearing the case, the Eighth Circuit stated that the record contained sufficient facts supported by evidence showing Plaintiffs were subject to a credible threat of adverse consequences by Defendants if they opposed their views on racism. As a result, the Eighth Circuit found that the record supported Article III standing as well as the chilled and compelled speech claims of Plaintiffs. However, the court denied Plaintiffs' request to be reassigned to a different judge. Plaintiffs alleged that the district court judge was hostile to their claims, but the Eighth Circuit stated that nothing in the district court's rulings and comments were of a nature that would establish bias or cause a reasonable person to question the judge's impartiality.
On January 27, 2026, Defendants filed another petition for a rehearing.
Litigation History
Significance
This case is one of many challenging public sector DEI training on free-speech grounds.