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About this filing
This archive page points to the Memorandum of Points and Authorities in Support of Plaintiffs' Motion for Temporary Restraining Order and Preliminary Injunction in Whitlow v. California. Filed with the opening papers on July 1, 2016, the memorandum explains why plaintiffs asked a federal court to pause SB 277 enforcement.
What this document is
The Whitlow complaint asked a federal court to review California's vaccination requirements for school enrollment. It is the opening pleading that framed the plaintiffs' claims against the state.
Why it matters
A complaint states the claims. A memorandum in support of emergency relief explains the irreparable harm, likelihood of success, and balance of equities. Together they show what plaintiffs asked the court to do before the school year hardened around the new enrollment rules.
Access note
The original WordPress PDF path for this filing is no longer available on edu4allnow.org. The memorandum remains a public court record. An external PDF mirror is available through the Bolen Report archive, and related case materials remain reachable through Casetext. This page keeps a stable Education For All URL for the old upload path.
That is why this page exists: preserve the old WordPress path as closely as Webflow allows, explain what the memorandum was, and point readers to surviving public copies of the document.
For families watching similar statutes elsewhere, Whitlow is more than California history. The memorandum in support shows how plaintiffs argued irreparable harm when school access was conditioned on compliance. That argument belongs in the public archive next to the complaint and amended complaint.
Readers should use Casetext for case materials and, where available, the external PDF mirror for a downloadable copy of the memorandum in support. Links can change. Hosts can disappear. The Education For All page remains the organized entry point for this filing.
Education For All treats the memorandum in support as a public resource. A complaint names the claims. This brief explains why emergency relief was requested on day one. When the old WordPress media URL broke, the organization still needed a stable page that points readers to surviving copies.
Education For All keeps this memorandum next to the complaint and amended complaint so readers can follow the emergency-relief request from the same week the case began. Short summaries cannot replace the primary brief that asked a federal judge to intervene before enrollment deadlines closed.
The July 1, 2016 memorandum argued that SB 277 would bar tens of thousands of California children from school by eliminating personal belief exemptions, and that emergency relief was needed to preserve the status quo while constitutional claims were heard. It framed the dispute around education access, parental decision making, free exercise, equal protection, and due process.