Efforts to censor library materials are fueling fights all over the country. ALA reported more than 700 book challenges in 2021, the most in 2 decades. In 2022, that number nearly doubled, and the number of targeted titles surged in 2023 to 4,240 unique titles. PEN America, one of the nation’s leading networks of writers, recorded more than 10,000 instances of public school book bans in the 2023–2024 school year, more than tripling the previous school year’s number. Of the most commonly banned titles, 57% included sex or sex-related topics and content, while 44% and 39%, respectively, featured characters or people of color and LGBTQ+ characters or people.

Florida led the nation in bans (4,561), with Iowa (3,671) not far behind. Other leading states include Texas (538), Wisconsin (408), Virginia (121), and Kentucky (100). The driver of these bans is often new state legislation. For instance, Florida’s House Bill 1069, which took effect in July 2023, created a statutory process for book banning. Iowa’s Senate Bill 496, which took effect in July 2023, prohibited materials that have any description or depiction of a “sex act.” It also outlawed discussions of LGBTQ+ identities in the classroom. In Montana, when passages from a book under consideration for banning were read aloud in the state Senate, one legislator replied, “It looks like there needs to be some book burning.” A Missouri statute, Mo. Rev. Stat. § 573.550, went so far as to criminalize the actions of anyone, including librarians, who provides access to a book deemed “sexually explicit.” Similarly, an Oklahoma law, Okla. Stat. tit. 70, § 11-202, singled out employees of schools and public libraries as eligible for criminal prosecution for exposing students to indecent material. 

Censorship exists in every era, of course, though the 1970s, like now, saw an upswing. It has many opponents. It also has defenders who are, if not as legion, just as vociferous. Ultimately, censorship is a question about what people should and should not know. Who has the right to opine? To report? To decide whether a thing is true or false? Righteous or wretched? Information or ignominy?

There have been many cases involving book bans over the years. One of the most crucial began in 1975 in Nassau County, New York: Board of Education, Island Trees Union Free School District No. 26 v. Pico, which stemmed from a school board’s desire to ban 11 books in its district:

• Oliver La Farge’s Laughing Boy
• Richard Wright’s Black Boy
• Bernard Malamud’s The Fixer
• Zoologist Desmond Morris’ The Naked Ape
• Down These Mean Streets, by the Afro-Cuban-Puerto Rican poet Piri Thomas
• Eldridge Cleaver’s Soul on Ice, which he wrote as an inmate at California’s Folsom State Prison
• Kurt Vonnegut’s Slaughterhouse-Five
• The Best Short Stories of Negro Writers, 1899–1967, edited by Langston Hughes
• The anonymous drug memoir Go Ask Alice
• Alice Childress’ A Hero Ain’t Nothin’ But a Sandwich
• A Reader for Writers, edited by Jerome W. Archer and Joseph Schwartz

No one had complained about these books. There had been no challenges, no letters to the editor, no public shouting matches. The Island Trees board was not reacting to worried parents or well-meaning quidnuncs, or even, in the words of Woody Allen, “one of those guys with saliva dribbling out of his mouth who wanders into a cafeteria with a shopping bag screaming about socialism.” 

The board simply acted. Like a sleeper cell.

In the process, it gave us the first, and so far, only, library book ban case to be decided by the U.S. Supreme Court. Immensely important, but with a complicated history, it was book banning’s Trial of the Century. Covered by The New York Times, The Washington Post, and other major newspapers, it was highly contentious, generating seven separate Supreme Court opinions—a steep number.

The case has been featured in journal articles, reprinted in law textbooks, highlighted in leading constitutional law treatises, and cited by hundreds of subsequent judicial decisions. Pico Vs Island Trees was an indie rock band in the early 2000s.

In “Read It and Weep,” an episode of TV’s Family Ties, Alex P. Keaton quotes from the case (“Local school boards may not remove books from school library shelves simply because they dislike the ideas contained in those books, and seek by their removal to prescribe what shall be orthodox in politics, nationalism, religion or other matters of opinion”) when he learns that Jennifer can’t do her book report on Huckleberry Finn because the school has banned it. 

Island Trees v. Pico deserves a place alongside the Supreme Court’s most famous disputes: Marbury v. Madison, Plessy v. Ferguson, Brown v. Board of Education, Roe v. Wade. Yet, in 2026, it is largely forgotten outside academe.

Now, I’m afraid, is the perfect time for a refresher.