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The North Star

“Right is of no Sex — Truth is of no Color.”

After Frederick Douglass, 1847

The free-speech desk — the First Amendment, censorship, and the right to be heard, tracked ruling by ruling across the fifty states.

Book Removals

A Maryland Judge Puts Flamer Back on the Library Shelf

A circuit judge upholds the state board and returns a graphic novel to Harford County school libraries, in the first real test of Maryland's Freedom to Read Act.

The North Star  •  By The North Star Desk  •  Compiled by the 10TOESDown Law Desk  •  October 22, 2026  •  3 min read  •  Maryland

Illustration: a book slid back into the gap it left.

Illustration: a book slid back into the gap it left. — AI-generated illustration

Harford County Circuit Judge Yolanda L. Curtin ruled from the bench that the county school board acted unlawfully when it removed Mike Curato's graphic novel Flamer from school library shelves. The decision leaves the Maryland State Board of Education's reversal intact.

Judge Yolanda L. Curtin of the Harford County Circuit Court ruled from the bench on Thursday that the county school board acted unlawfully when it pulled Mike Curato's graphic novel Flamer from school library shelves in June 2025. The decision leaves standing the Maryland State Board of Education's November 2025 reversal of that removal, and returns the book to circulation.

The case is the first significant test of Maryland's Freedom to Read Act, the 2024 statute barring school systems from removing library material because of partisan, ideological or religious disapproval. The state board had found the local board fell short of that standard, noting that nothing in the record suggested its members read the book beyond selected passages.

Curtin reviewed the state board's decision for arbitrariness rather than writing on a blank slate, and found no fault with it. Reporting on the ruling describes her as holding that the removal violated both the statute and the First Amendment.

What makes this worth watching is less the book than the standard. A state statutory floor, enforced in state court, operates independently of the federal case law now splintering across the circuits. Districts in states with comparable read-freely statutes have a decision to reckon with.

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Statistic label

This court finds that the decision by the state board was not arbitrary, unreasonable or illegal.

— Judge Yolanda L. Curtin, Harford County Circuit Court

Video caption

How the case moved

JUNE 2025

The Harford County Board of Education votes to remove Flamer from school libraries.

NOVEMBER 2025

The Maryland State Board of Education reverses the removal under the Freedom to Read Act.

OCT. 22, 2026

Judge Curtin upholds the state board from the bench.

✓  Fact check

Claim

Claim text

Reality

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Legal References

Bluebook citation · cases, statutes & the record

Primary legal authority cited in this report. Links go to the public record where one exists.

[1]

Maryland Freedom to Read Act, HB 785 (2024) ¶ source

Maryland General Assembly 2024

Academic References

ABA / law-review style · secondary scholarship

Secondary scholarship that informs the analysis.

[1]

Reference text

#BookBans

#Maryland

#FreedomToReadAct

#SchoolLibraries

#FirstAmendment

Author bio

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