Written by: Gloria Kosir 

Jill Wieber Lens, the Dorothy M. Willie Professor in Excellence at the University of Iowa College of Law, was cited in a Fourth Circuit judge’s concurring opinion in PFLAG, Inc. v. Trump. Her article, “Stays of Injunctive Relief Pending Appeal: Why the Merits Should Not Matter,” was published in the Florida State University Law Review in 2016.

The federal lawsuit was filed to challenge two Trump administration executive orders, which aimed to withhold federal funding from medical providers offering gender-affirming care to individuals under age 19. About a year after a federal district enjoined enforcement of the executive order in March 2025, the government sought a stay of the injunction at the Fourth Circuit Court of Appeals, where a panel of judges denied the stay. 

Lens’ article was cited in Judge DeAndrea Gist Benjamin’s concurring opinion, in which the full court denied petition for rehearing en banc. Lens' article argues that “courts should look to whether a stay is necessary—due to any potentially changing circumstances, harm to the parties, and the public interest.”