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JAMMED LOCKER: HOW THE ELEVENTH CIRCUIT'S DECISION IN
ADAMS V. SCHOOL BOARD OF ST. JOHNS COUNTY MAY JAM UP
TRANSGENDER STUDENTS' RIGHTS
ERIN WILSON*
I. NEW YEAR, SAME RULES: AN INTRODUCTION TO THE SCHOOL BATHROOM
ENVIRONMENT FOR TRANSGENDER STUDENTS
Picture this: a young, transgender student is starting their first day of high
school, nervous but hopeful that they will fit in with their peers.1 Before the first
bell, the student decides to go to the bathroom.2 As the student enters the bathroom
that aligns with their gender identity, a teacher suddenly stops them.3 The teacher
loudly announces that the school prohibits them from using the bathroom that
aligns with their gender identity in front of all of their classmates.4 Embarrassed and
ashamed of the scene the student caused-for simply wanting to use the bath-
room-the student slowly turns away and does not use the bathroom at all.5
While this humiliating incident may sound unique, it happens to transgender
students across America.6 In fact, these bathroom policies are so prominent that for
*J.D. Candidate, 2025, Villanova University Charles Widger School of Law; B.S., 2022, The
University of Scranton. This Note is dedicated to my parents and brother who continuously sup-
port me in everything I do. I would also like to thank the members of the Villanova Law Review for
their feedback throughout the editing process.
1 See Grimm v. Gloucester Cnty. Sch. Bd., 972 F.3d 586, 598 (4th Cir. 2020) (discussing
transgender student Gavin Grimm's experience using the bathroom that aligned with his gender
identity at school), as amended (Aug. 28, 2020), cert. denied, 141 S. Ct. 2878 (2021) (mem.). Grimm
transitioned to male during his first years of high school and wanted his peers and the school to
treat him as a male. Id.
2 See id. (discussing how Grimm consistently used the men's bathrooms in public with no
issues).
3 See id. (noting how Grimm spoke with his school's guidance counselor and principal about
using the men's bathroom at school). Once Grimm had fully transitioned, he spoke to school
administration and explicitly requested access to the men's bathroom, which, following delibera-
tion, the school's principal granted. Id.
4 See id. at 600 (describing how after a school vote, the school's principal revoked Grimm's
access to the men's bathroom). After receiving a myriad of complaints from parents in the school
district, there was a 6-1 vote to ban Grimm's access to the men's bathroom at school. Id.
s See id. (discussing how Grimm stopped using the bathroom at school because he was denied
access to the men's bathroom). Grimm began practicing restroom avoidance at school, which
resulted in Grimm experiencing reoccurring urinary tract infections. Id.
6 See Megan Nicolaysen, Note, The Bathroom Stall: How LegalIndedsion Regarding TransgenderBath-
room Access Has Led to Discriminaton, 61 U. LOUISVILLE L. REv. 175, 185-86 (2022) (describing the
discrimination that transgender students face due to discriminatory bathroom policies). Nicolaysen
begins the bathroom discussion with a simple phrase: [t]ransgender discrimination happens fre-
quently, and bathrooms are at the center of such discrimination. Id. at 185. Nicolaysen then notes
how the gap in legal protections for transgender students allow schools across the United States to
implement restrictive, discriminatory bathroom policies. Id. at 186; see also Grimm, 972 F.3d at 597
(noting that according to the 2015 U.S. Transgender Survey, fifty-eight percent of transgender stu-
dents feel discouraged from using school bathrooms that align with their gender identity based on
schools' discriminatory policies); Erik Fredericksen, Note, Protecting Transgender Youth AfterBostock:](ViewImageLocal?handle=hein.journals/vlrtoleg69&div=1&collection=&method=preview&ext=.png&size=3)
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