A federal judge has struck down a transgender athlete’s attempt to voluntarily dismiss her long-running lawsuit against Idaho’s Fairness in Women’s Sports Act, ensuring the challenge to the controversial law remains alive and on track for review by the U.S. Supreme Court.
In a Memorandum Decision and Order issued on October 14, 2025, U.S. District Court Chief Judge David C. Nye GRANTED Defendants’ (Governor Bradley Little, et al.) Motion to Strike the Notice of Voluntary Dismissal filed by plaintiff Lindsay Hecox. Hecox is a transgender woman who sought to compete in women’s sports at Boise State University but was blocked by the Act, which became law in March 2020.
Avoidance of Supreme Court Review
The decision hinges on the existing, all-encompassing stay that the court had placed on the case pending the outcome of Governor Little’s petition for a writ of certiorari to the Supreme Court. That petition was granted on July 3, 2025.
Hecox filed her Notice of Voluntary Dismissal on September 2, 2025, citing “significant personal and family challenges” and her decision to no longer pursue collegiate sports. The dismissal, filed under Federal Rule of Civil Procedure 41, would normally be self-executing.
However, the court found that Hecox’s action “contravenes the stay currently in place and flaunts principles of equity and fairness and is, thus, void.”
Judge Nye stressed the importance of a final resolution, stating that the parties and the public have a “vested interest in finality on the issues presented in this case.” He also noted that Hecox’s dismissal at this stage, without vacating the Ninth Circuit Court of Appeals decisions that had affirmed the preliminary injunction against the Idaho law, would leave critical legal questions “in limbo.”
Idaho Attorney General Praises Ruling
Idaho Attorney General Raúl Labrador, whose office has vigorously defended the law, issued a statement applauding the ruling.
“From day one in office, defending this law has been a top priority because Idaho’s daughters deserve fair competition based on biological reality,” Labrador said. “The district court has ruled that after years of litigation, Idaho has earned the right to present our case to the nation’s highest court.”
The Alliance Defending Freedom (ADF), which is representing clients in the case, also voiced approval. ADF Senior Counsel John Bursch stated, “We are pleased the district court rejected the attempt to end this case before it is argued before the U.S. Supreme Court.”
Case History and Legal Strategy
The lawsuit, Hecox v. Little, has been in constant motion since 2020, moving between the District Court and the Ninth Circuit. The case’s complex history includes multiple affirmances and remands on issues of standing and the scope of injunctions.
The court ultimately sided with the Defendants, who argued that Hecox had waived her right to file the dismissal by agreeing to a stay of “all proceedings” until the Supreme Court issued a final ruling. The court also expressed concern over the plaintiff’s strategic use of dismissal to avoid Supreme Court review, especially since the state’s petition for certiorari had already been granted.
With the ruling, the case remains active and pending as it heads to the Supreme Court, where it will likely be heard alongside a similar case challenging a West Virginia law. The high court’s decision will have nationwide implications for the legal status of transgender athletes in women’s sports.
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