Who’s Afraid of the First Amendment?
Richard McDaniel
Research Associate, World Without Genocide
Book banning isn’t new. Prior to the 1970s, books were banned or challenged — commonly by religious leaders and their ideologies, such as Anthony Comstock, a 19th-century anti-vice activist— if they were deemed obscene or sexually explicit. [1] Books such as James Joyce’s Ulysses and D.H. Lawrence’s Lady Chatterly’s Lover were regularly targeted. Beginning in the late 1970s, books were targeted due to the ideologies that they expressed. By September 1990, the Thomas Jefferson Center for the Protection of Free Expression claimed that the First Amendment was “in perilous condition across the nation,” especially since books such as Mark Twain’s Adventures of Huckleberry Finn and Maya Angelou’s I Know Why the Caged Bird Sings were targeted. [2]
While book banning isn’t new, censorship has occurred with unprecedented intensity in recent years. The American Library Association recorded attempts to remove 2,452 unique book titles in 2024, which exists in stark contrast to the average of 273 unique titles challenged annually between 2001 and 2020. [3] Between July 2024 and June 2025, PEN America similarly found that 6,870 books were pulled from school libraries across 23 states. [4] The vast majority of book banning instances occur in Florida, Texas, Tennessee, Missouri, and Utah. Examples include the following:
- In Florida, 2,304 books were banned during the 2024-2025 school year. [5]
- In Texas, 1,781 books were removed from libraries during that same year. [6]
- In July 2025, nearly 600 books were removed from the Department of Defense Education Activity (DoDEA) schools on military bases. [7]
The books that have been removed from school libraries are often targeted because they have themes, characters, or authors associated with the LGBTQ+ or BIPOC communities. [8] The American Library Association found that books have also been banned due to their portrayal of drug use and political or religious viewpoints. [9] According to PEN America, Stephen King was the most banned author over the last school year. King’s books were banned 206 times, and 87 of his titles were affected. [10] Furthermore, the most banned title was A Clockwork Orange, which was removed from school libraries 23 times. [11] Other authors who have been affected by widespread book banning include Toni Morrison, Sally Rooney, and Kurt Vonnegut. [12]
Book banning isn’t the only problem facing education. As part of its effort to eliminate the Institute of Museum and Library Services, the Trump administration suspended millions of dollars in federal grants. [13] As a result, libraries across the country have been reducing their amount of e-books, audiobooks, and loan programs. Teachers have also been under attack over the last few years. For example, in 2023 a Texas middle school teacher was fired for assigning an illustrated adaptation of Anne Frank’s diary. [14] In 2022, an Oklahoma high school teacher was put on administrative leave after she explained to students how to access banned books through a New York library. [15]
Of course, none of this is remotely legal. In Tinker v. Des Moines, the majority opinion of the Supreme Court (1968) ruled that the First Amendment includes the right of students to freely receive information and express ideas. [16] In Island Trees Union Free School District v. Pico, the majority opinion of the Supreme Court (1982) ruled that while public schools can prohibit books that are “pervasively vulgar” or lack relevance to the curriculum, schools cannot remove books “simply because they dislike the ideas contained in those books.” [17] Unfortunately, many books have been forcibly removed from school libraries simply because they give visibility to marginalized communities or offer different viewpoints.
In Minnesota, the state legislature passed a bill in 2024 to prevent book bans. [18] Minnesota is one out of only six states (including Colorado, Illinois, Washington, Vermont, and Maryland) that have passed legislation to curtail the banning of books. However, censorship still occurs across many Minnesota school libraries. In December 2024, the St. Francis School Board in St. Francis, Minnesota passed a policy that granted a website, Booklooks.org, authority over which books would be offered at St. Francis school libraries or would be purchased by the district. On the website, books that contain LGBTQ+ characters, BIPOC themes, or “inflammatory religious content” were rated as less appropriate and were subsequently removed from school libraries. [19] Books that were banned included Brave New World, The Handmaid’s Tale, and Night by Holocaust survivor Elie Wiesel. Eventually, the St. Francis School Board was sued and returned dozens of banned books to school facilities.
Still, “quiet banning” or self-censorship commonly occurs across many Minnesota school libraries. According to PEN America, the vast majority of book bannings aren’t the direct result of legislation, but are rather the consequence of fear of legislation by school boards, administrators, and educators. [20]
In conclusion, the words by a PEN America leader, Sabrina Baêta, express a strong message.
“No bookshelf will be left untouched if local and state book bans continue wreaking havoc on the freedom to read in public schools…With the Trump White House now also driving a clear culture of censorship, our core principles of free speech, open inquiry, and access to diverse and inclusive books are severely at risk. Book bans stand in the way of a more just, informed and equitable world. They chill the freedom to read and restrict the rights of students to access information and read freely.” [21]
Written by Richard McDaniel, November 2025.
References
[1] Webb, S. L. (2023, August 8). Book Banning. Free Speech Center at Middle Tennessee State University. www.firstamendment.mtsu.edu/article/book-banning/#
[2] Ibid.
[3] American Library Association (n.d.). Book Ban Data. American Library Association. www.ala.org/bbooks/book-ban-data
[4] Newsweek. (2025, October 9). Map Shows States That Have Banned Most School Books. Newsweek. www.newsweek.com/map-states-banned-school-books-10852349
[5] Ibid.
[6] Ibid.
[7] PEN America. (2025, October 1). The Normalization of Book Banning. PEN America. www.pen.org/report/the-normalization-of-book-banning/
[8] Contreras, V. (2025, July 10). Book bans seemingly continue after being prohibited in Minnesota. The Minnesota Daily. www.mndaily.com/294761/uncategorized/book-bans-seemingly-continue-after-being-prohibited-in-minnesota/
[9] Ibid.
[10] Newsweek. (2025, October 9). Map Shows States That Have Banned Most School Books. Newsweek. www.newsweek.com/map-states-banned-school-books-10852349
[11] Ibid.
[12] Marcos, C. M. (2024, November 12). Florida officials report hundreds of books removed from schools. The Guardian. www.theguardian.com/us-news/2024/nov/13/florida-book-bans-removals-education-department-list
[13] Lathan, N. (2025, May 17). Libraries are cutting back on staff and services after Trump’s order to dismantle small agency. The Associated Press. www.apnews.com/article/institute-museum-library-services-funding-cuts-trump-d3a236243b3a5c2b04e85d2004d1a946
[14] Oladipo, G. (2023, September 20). Texas teacher fired for showing Anne Frank graphic novel to eighth-graders. The Guardian. www.theguardian.com/us-news/2023/sep/20/texas-teacher-fired-anne-frank-book-ban
[15] Orecchio-Egresitz, H. & Niemeyer, K. (2022, August 23). An Oklahoma school district put a teacher on leave after she shared a link to Brooklyn library’s banned book site. Business Insider. www.businessinsider.com/oklahoma-teacher-leave-after-sharing-link-to-banned-books-2022-8
[16] Webb, S. L. (2023, August 8). Book Banning. Free Speech Center at Middle Tennessee State University. www.firstamendment.mtsu.edu/article/book-banning/#
[17] Ibid.
[18] Contreras, V. (2025, July 10). Book bans seemingly continue after being prohibited in Minnesota. The Minnesota Daily. www.mndaily.com/294761/uncategorized/book-bans-seemingly-continue-after-being-prohibited-in-minnesota/
[19] Education Minnesota. (2025, June 10). St. Francis schools agree to settle lawsuits over book bans filed by ACLU, union. Education Minnesota. www.educationminnesota.org/news/press-release/st-francis-settles-lawsuits-over-book-bans/
[20] PEN America. (2025, October 1). The Normalization of Book Banning. PEN America. www.pen.org/report/the-normalization-of-book-banning/
[21] PEN America. (2025, October 1). Latest PEN America Report Finds “Disturbing Normalization” of Book Bans in Public Schools. PEN America. www.pen.org/press-release/latest-pen-america-report-finds-disturbing-normalization-of-book-bans-in-public-schools/