The U.S. is seeing a steady rise in book bans, with a 33% increase in the 2022-2023 school year.[1] Florida has taken the lead, accounting for 40% of all book bans nationwide in the 2022-2023 school year,[2] and a total of 37 states have recorded official book bans as of April 2023.[3] Although the Maryland General Assembly has yet to propose formal legislation banning books, and Governor Wes Moore has openly expressed his discontent with this trend[4] — it seems Maryland may soon become the next victim of literary censorship.[5]
The conservative non-profit organization Moms for Liberty has been a nationwide leader in the movement for book bans since its inception in January 2021.[6] The organization has local chapters nationwide, including ten in the state of Maryland.[7] In September 2023, Carroll County public schools pulled over fifty books from library shelves for review and further consideration of permanent removal.[8] In the same week, Harford County saw similar actions from the school board, with the formation of a book review committee.[9] Local Moms for Liberty chapter representatives led the initiatives in both counties.[10] Melissa Hahn and Diane Alvarez, Harford County School Board members, were endorsed by the local Moms for Liberty chapter in the 2022 school board election.[11] Two additional members, Lauren Strauss and Terri Kocher, also reportedly have close ties to the group.[12] In Carroll County, Moms for Liberty endorsed two current board members, Tara Battaglia and Steve Whisler, as well as two candidates running in the 2024 Board of Education election, Greg Malveaux and Kristen Zihmer.[13]
Books submitted for review by Moms for Liberty primarily consist of subject matters including LGBTQ+ themes, primary or prominent characters of color, sexual content, themes of social rights and activism, and stories with religious minorities.[14] Parents, students, and critics have voiced concern over the restrictions in both counties, with some calling it a First Amendment violation.[15] The Harford County School Board responded, stating it did not create a book review committee, but rather “a workgroup to review the existing practices of the evaluation and selection of library materials and the reconsideration process of challenged library materials[…].”[16]
Meanwhile, the review committee in Carroll County is struggling to keep up with the increased number of requests submitted.[17] As of September 2023, 58 books have been submitted for review, including the likes of The Kite Runner by Khaled Hosseini and The Perks of Being a Wallflower by Stephen Chbosky.[18] The review process only allows five books per month to undergo evaluation.[19] While a book is in queue for review, it is taken off of library shelves until the committee has studied it and issued a decision.[20] Superintendent of Carroll County, Cynthia McCabe, stated that the current system was never designed to receive such an influx of requests.[21] The system was created with the expectation of receiving four or five requests per year, and simply cannot keep up.[22] Meanwhile, books that will not be reviewed for months are being pulled from library shelves.[23]
Critics of Moms for Liberty, and book bans generally, have expressed unease with the rise in censorship, linking it to increases in racism and LGBTQ+ discrimination.[24] The question of First Amendment protections is also important here.[25] In accordance with Supreme Court jurisprudence protecting First Amendment freedoms, the National Coalition Against Censorship (NCAC) and the American Library Association (ALA) have created guidelines for assessing formal complaints to school library collections.[26] However, an analysis by PEN America found that a staggering 98% of book bans departed from the best practice guidelines provided by the ALA and NCAC to preserve students’ First Amendment rights.[27] PEN America noted a specific example in Wicomico County, Maryland.[28] There, the superintendent removed All Boys Aren’t Blue by George M. Johnson following a board meeting where attendees voiced concern with the book’s subject matter.[29] No formal request or complaint had been filed with the school board.[30]
Book bans are sweeping across America like the fires of Fahrenheit 451, and Maryland could soon be engulfed. With the steady increase of book challenges across the state, Carroll and Harford Counties may be the first of grave concern when it comes to literary liberty and First Amendment protections. However, it is unlikely these counties will be the last.

Sienna Duran-Kneip is a second-year J.D. Candidate at the University of Baltimore School of Law and a Staff Editor for Law Forum. Sienna graduated from Chapman University in 2019 with a double major in Economics and Spanish, and a minor in Italian Studies. She works as a Paralegal/Case Manager at Kreindler & Kreindler, LLP, specializing in September 11th Victim Compensation Fund claims. During the summer of 2023, Sienna interned with Human Rights First on the D.C. Refugee Representation team. At UB, she serves as the Secretary of the International Law Society, 2L Representative for the Latin American Law Student Association, and is a member of the 2023-2024 Jessup International Law Moot Court team. Upon completion of her J.D., Sienna plans to continue her legal education abroad, pursuing an LLM in international human rights law.
[1] New Report: Book Bans Spike by 33% Over Last School Year, PEN Am. (Sept. 21, 2023), https://pen.org/press-release/new-report-book-bans-spike-by-33-over-last-school-year/#:~:text=(NEW%20YORK)%20—%20The%20number,a%20new%20PEN%20America%20report.
[2] Id.
[3] Kelly Jensen, 37 States and Millions of Students Impacted by 2022-2023 School Year Book Bans So Far: PEN America’s Latest Report, Book Riot (Apr. 20, 2023), https://bookriot.com/pen-america-book-ban-report-2023/.
[4] Olafimihan Oshin, Maryland Governor Says Book Bans Are “Castrating” Kids, The Hill (June 18, 2023, 4:35 PM), https://thehill.com/homenews/state-watch/4056177-maryland-governor-says-book-bans-are-castrating-kids/.
[5] Caroline Foreback & Kelsey Kushner, Carroll County School Board Steps in As Parents Battle Over Controversial Library Books, CBS News Balt. (Sept. 13, 2023, 4:56 PM), https://www.cbsnews.com/baltimore/news/carroll-county-school-board-to-review-after-group-calls-for-removal-of-dozens-of-library-books/.
[6] Odette Yousef, Moms For Liberty Among Conservative Groups Named ‘Extremist’ by Civil Rights Watchdog, Nat’l Pub. Radio (June 7, 2023, 2:54 PM), https://www.npr.org/2023/06/07/1180486760/splc-moms-for-liberty-extremist-group.
[7] Moms for Liberty, https://www.momsforliberty.org (last visited Oct. 21, 2023).
[8] Tim Tooten, Carroll County Schools Consider Book Ban After Parental Concern, WBAL-TV (Sept. 13, 2023, 9:28 AM), https://www.wbaltv.com/article/book-ban-carroll-county-schools-review-parent-concern/45107473.
[9] Katia Parks, Book Review Committee Prompts Concern, Balt. Sun (Sept. 13, 2023), https://www.proquest.com/baltimoresun/docview/2864100331/CC891B1BF7004518PQ/11?accountid=40537.
[10] Foreback & Kushner, supra note 5; Parks, supra note 9.
[11] Parks, supra note 9.
[12] Id.
[13] Cindy Rosenberg, Commentary: How Moms for Liberty and the Book-Banning Movement Got Here, Balt. Banner (Sept. 27, 2023, 5:30 AM), https://www.thebaltimorebanner.com/carroll-county/carroll-county-moms-for-liberty-books-EPCJY47KFZEERHMZFXPHS3UCUM/.
[14] Jonathan Friedman & Nadine Farid Johnson, Banned in the USA: The Growing Movement to Censor Books in Schools, PEN Am. (Sept. 19, 2022) https://pen.org/report/banned-usa-growing-movement-to-censor-books-in-schools/.
[15] Kristen Griffith, Moms for Liberty Is Winning Its Fight to Remove Books from One Maryland School District, Balt. Banner (Sept. 13, 2023, 3:26 PM), https://www.thebaltimorebanner.com/education/k-12-schools/carroll-county-maryland-schools-moms-for-liberty-ISZJNQBQKRAPFD35ZEAG3X47KY/.
[16] Katia Parks, Board Members Name 6 Books Parents Deem Inappropriate, Balt. Sun (Sept. 29, 2023), https://www.proquest.com/baltimoresun/docview/2871734147/CC891B1BF7004518PQ/6?accountid=40537.
[17] Griffith, supra note 15.
[18] Rosenberg, supra note 13.
[19] Id.
[20] Id.
[21] Griffith, supra note 15.
[22] Id.
[23] Id.
[24] Rosenberg, supra note13.
[25] Jonathan Friedman & Nadine Farid Johnson, Banned in the USA: Rising School Book Bans Threaten Free Expression And Students’ First Amendment Rights, PEN Am. (Apr. 2022), https://pen.org/banned-in-the-usa/.
[26] Id.
[27] Id.
[28] Id.
[29] Id.
[30] Id.






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