Illinois National Guard distributes compliance guide requiring restroom designation by biological sex (the "Garrison Memorandum")

Institutional compliance

Date
Actor
Colonel Matthew Garrison, Chief of Joint Staff, Illinois National Guard; Illinois National Guard Human Resource Office
Type
Institutional compliance
Section
SUPPLEMENT: THE FEDERAL-WORKPLACE RESTROOM AND SINGLE-SEX-FACILITIES BAN: OPERATIVE DIRECTIVES AND THE WITHROW CLASS ACTION ARE BOTH MISSING

Summary

Colonel Garrison distributed to all full-time Illinois National Guard employees a "quick reference guide on the executive orders and subsequent [National Guard Bureau] guidance with relevance to ILNG," prepared by the ILNG Human Resource Office and titled "ILNG-HRO, EO-PM Summary Impact." The document summarizes EO 14168 as requiring the agency to "ensure intimate spaces are designated by biological sex" and states that the Illinois National Guard would "need to confirm compliance with . . . restrooms." A related HRO transmission bearing a February 3, 2025 signature by Colonel Daly stated the need "to confirm compliance with media, pronouns, restrooms, etc." This is the document that reached LeAnne Withrow's workplace directly and is the state-level template for parallel implementation in other states' National Guards.

Status

In effect. Pleaded as an Agency Implementation Action in Withrow; the government has argued in its motion to dismiss that this state-level memorandum, rather than any federal directive, is what actually restricted Withrow's restroom use — an argument plaintiff uses to show the federal directives afforded no discretion below.

As recorded in the data of . Check the sources for anything newer.

Related litigation

Sources