The Eleventh Circuit Court of Appeals recently ruled on a significant case involving four students from the Cobb County School District in Georgia. The students, who have disabilities that make them more vulnerable to respiratory viruses, challenged the school district’s decision to prohibit mandatory mask mandates during the COVID-19 pandemic. This ruling affects how schools can respond to health crises and the rights of disabled students to receive accommodations.
The case, L.E. v. Superintendent of Cobb County School District, was filed on August 5, 2026, under docket number 23-11741. The students, represented by their parents, argued that the school district's new policy violated their rights under the Americans with Disabilities Act (ADA) and the Rehabilitation Act (RA). The court's decision highlights the ongoing debate over health policies in schools and the protections afforded to students with disabilities.
Background
The plaintiffs in this case are four students: L.E., B.B., A.Z., and C.S., all of whom attended public schools in Cobb County, Georgia. Each of these students has disabilities that make them particularly susceptible to respiratory illnesses, including COVID-19. When the pandemic began in March 2020, the Cobb County School District closed schools and later implemented various health measures, including mask mandates, in line with CDC guidelines.
As the 2021-2022 school year approached, the school district changed its policy, opting to ban mandatory masking. This decision prompted the students' parents to withdraw them from school and request the reinstatement of previous COVID-19 precautions. The school district refused, citing its new policy, which led the students to attend classes virtually or enroll in private schools. The students then filed a lawsuit against the school district, claiming that the prohibition on mask mandates discriminated against them and denied them equal access to education.
The Ruling
The Eleventh Circuit Court of Appeals reviewed the case and made several key rulings. The court reversed the lower court's decision that dismissed two of the students, A.Z. and C.S., for lack of standing due to their enrollment in private schools. The court stated, "The district court erred when it assessed A.Z.’s and C.S.’s standing differently from the still-enrolled students." This means that the court recognized that the students still had claims related to past discrimination, even if they were no longer enrolled in the district.
However, the court upheld the lower court's decision to deny the other two students, B.B. and L.E., a preliminary injunction. The court found that these students had not demonstrated a substantial likelihood of success on the merits of their claims under the ADA and RA. The judges noted that the school district had provided reasonable accommodations, such as preferential seating and access to less crowded facilities, which allowed the students to attend in-person schooling as their health permitted.
Impact
This ruling has significant implications for students with disabilities and school policies regarding health and safety measures. It clarifies that while schools must consider individual accommodation requests, they are not required to adopt blanket policies that may not be feasible. The court emphasized that the focus should be on the students' access to in-person education rather than on general health policies.
The decision also sets a precedent for how courts may interpret the ADA and RA in the context of public health emergencies. Schools must balance the need to protect all students with the rights of those who may require additional accommodations due to disabilities. This case may influence future litigation involving school policies and health guidelines, particularly as schools navigate ongoing public health challenges.
What's Next
The students may seek to appeal the court's decision, particularly regarding the denial of the preliminary injunction for B.B. and L.E. However, details about any potential appeal were not available in the court filing. The outcome of this case could have lasting effects on how schools implement health policies and accommodate students with disabilities in the future.