9th Cir.

Roe v. Johnston

April 28, 2026 ·25-6970 ·Published · By Aisha Johnson

The Ninth Circuit granted a stay pending appeal of a district court order that had struck the word operation from an Arizona statute governing birth certificate amendments. The panel paused the injunction to preserve the status quo while it considers the merits of the appeal regarding transgender rights.

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Background

Plaintiffs, a class of transgender people in Arizona, sued the Director of the Arizona Department of Health Services, alleging that A.R.S. Section thirty-six three hundred thirty-seven subsection A three violates the Equal Protection and Due Process Clauses. The statute required the registrar to amend a birth certificate only upon verification that the individual had undergone a sex change operation. The district court granted summary judgment for the plaintiffs and entered a permanent injunction striking the word operation from the statute, with an effective date of April thirtieth, two thousand twenty-six.

The court’s reasoning

The panel applied the four-factor test from Nken versus Holder to determine whether a stay pending appeal was warranted. The factors include whether the applicant has made a strong showing of likely success on the merits, whether the applicant will suffer irreparable injury absent a stay, whether the stay will substantially injure other parties, and where the public interest lies. The panel found that a stay was warranted to preserve the status quo while the court decides the merits of the appeal.

What it means going forward

The permanent injunction striking the word operation from the Arizona birth certificate statute is paused and will not take effect on April thirtieth, two thousand twenty-six, until the Ninth Circuit issues a decision on the merits.