Adventures in misleading headlines

Some Iowa news headlines misrepresented an Eighth Circuit Court of Appeals decision on February 27, which resolved a long-running lawsuit over Iowa’s 2021 law banning schools from requiring masks.

“Federal appeals court upholds Iowa law banning school mask mandates,” read the headline on a Cedar Rapids Gazette story, also published in some of the Lee Newspapers.

KCRG-TV’s version (carried by other television stations with the same owner) was titled “Federal appeals court upholds Iowa ban on mask mandates.”

“Appeals court upholds law banning mask mandates in schools,” read the headline on Iowa Capital Dispatch, a website that allows Iowa newspapers to republish its reporting at no charge.

The framing closely tracked written statements from Governor Kim Reynolds and Attorney General Brenna Bird, who hailed the Eighth Circuit decision.

There was just one problem: the appeals court did not “uphold” the law.


The decision by a three-judge panel does leave Iowa’s law in effect. However, it did not consider the merits of the claims the plaintiffs raised.

Rather, the appeals court vacated the November 2022 order by U.S. District Court Judge Robert Pratt on the grounds that the plaintiffs (the disability advocacy organization Arc of Iowa and families with school-age children) lacked standing to bring the case.

The children involved have disabilities or medical conditions making them particularly vulnerable to COVID-19 infections. Pratt had ruled that such students “may request a reasonable accommodation that requires masks to be worn by teachers, aides, other students, and anyone else near or interacting with the disabled student,” and school districts must consider such a request, “just as they would any other request for a reasonable modification made under the ADA [Americans with Disabilities Act] or the Rehabilitation Act.”

The February 27 opinion by Circuit Court Judge Ralph Erickson, joined by Judges Duane Benton and Jonathan Kobes, held that the plaintiffs failed to show they suffered “an injury in fact.” Rather, they “have only alleged the potential risk of severe illness should they contract COVID-19 at school,” which the judges found “too speculative to satisfy the injury in fact element.”

In addition, the plaintiffs failed to show that the named defendants (Governor Reynolds and then Iowa Department of Education Director Ann Lebo) had attempted to enforce the state law in a way that directly affected the vulnerable students.

Although the plaintiffs “asserted ‘rights’ that it believed schools should be given with regard to masking in schools,” the ten school districts that were also named defendants in Arc of Iowa v Reynolds did not appeal the lower court ruling. Therefore “the precise nature of any ongoing dispute is unclear to us.”

The judges noted that Iowa’s ban on school mask mandates “does not prohibit a school from complying with disability laws,” if a family requested “masking as a reasonable accommodation tailored to their child’s situation.”

The Eighth Circuit remanded the case to U.S. District Court with instructions to dismiss for lack of standing.


Before many reporters had a chance to read the appeals court decision, they received news releases that encouraged them to misinterpret the ruling.

The governor’s statement put the phrase “upholding Gov. Reynolds’ Mask Mandate Prohibition in Schools” in the email subject line as well as at the top of the news release. Reynolds’ comments bashing “COVID lockdowns and mandates” had little to do with the legal issues at hand. As she has done many times, she boasted about prohibiting mask mandates and “trusting parents to decide what was best for their children.”

The press release from the Attorney General’s office likewise used the phrase “Ruling to Uphold Iowa Law Banning School Mask Mandates” in the subject line. The opening sentence referred to Bird’s statement “applauding a federal court’s ruling to uphold Iowa’s law banning school mask mandates.” The quote from Bird (included in some news reports) reinforced the frame a third time: “Freedom wins in today’s court ruling to uphold Iowa’s law banning mask mandates in schools. Parents have the right to choose what healthcare decisions are best for their kids.”

What’s best for kids with fragile health has never factored into Bird’s or Reynolds’ calculations. But the Eighth Circuit made clear that under Iowa’s law, parents of such children can request that schools require students and staff who interact with them to wear masks. Many news organizations published the Republican officials’ comments without explaining that aspect of the ruling. KCRG’s news brief gave more space to the governor’s statement than to any explanation of the legal context.


Some news organizations found a better way to introduce the appeals court’s decision to readers. The Associated Press article by Hannah Fingerhut (also published on some newspaper and broadcast media websites) was titled, “Federal court dismisses case against Iowa governor’s ban on school mask mandates.”

The headline on the Des Moines Register story by William Morris described the legal landscape in a more complete way: “Appeals court tosses Iowa mask mandate lawsuit, affirms schools must follow disability law.”

Bret Hayworth’s news brief for KWIT (Sioux City’s public radio station) had the title “Federal court ends appeal case against Iowa abolition of school mask mandates.”

Radio Iowa’s story had a good headline—”Federal appeals court rules on Iowa law banning school mask mandates”—but fell down on the first sentence: “A federal appeals court has upheld a 2021 state law that bans schools from issuing mask mandates.”

To be fair, editors may write or alter a headline without input from reporters. Both the Iowa Capital Dispatch story by Clark Kauffman and the Cedar Rapids Gazette story by Caleb McCullough accurately characterized the substance of the Eighth Circuit decision.

But headlines reach far more people than the body of a news story. Most people who see the headline on a social media platform or email newsletter won’t click through to read the article. Even those who subscribe to a newspaper or deliberately visit a website may not get far past the headline.

A misleading headline can influence those who go on to read the whole story as well, by framing the topic before readers absorb the “who, what, where, when, and why” details.

It’s likely that many Iowans now have the wrong impression that the Eighth Circuit Court of Appeals validated or even endorsed Iowa’s ban on school mask mandates. Reynolds and Bird have every incentive to promote that view. But journalists and editors should be careful not to let official spin set the news agenda.

About the Author(s)

Laura Belin

  • thanks for this

    was insult to injury to read what was being published, better check our records for measle shots…

  • kids should come first

    Journalists argue about the proper title of a ruling,
    While parents remember the pandemic.

    To protect our kids from a threat that was not theirs
    Schools closed for months.
    School boards fought to prevent kids from learning
    They fought tooth and nails

    Teachers promised that kids would learn remotely
    Tucked in bed, kids slept on their Chromebooks
    A predictable yet unbelievable damage
    Why learn when AI will think for them

    Of course, remote learning does not work with kids
    Otherwise, schools would teach remotely during snow days
    Black, poors, kids from single parents working two jobs
    Kids who need school the most,
    Thes kids fell behind the most

    Big Pharma told us to get vaccines asap,
    Then twice, every season, then every month,
    Until most of us stopped listening
    Many young athletes fell, their hearts burning

    Yes indeed many died from COVID
    Most being old, obese or sick
    Or all of the above, out of shape as we have become
    Many more died than in poor countries without vaccines

    Remember, we stopped counting deaths from the flu
    How convenient, these arrangements with the truth
    Statistics and history are often those of the winner
    Although we forgot who was the winner

    Parents remember how our country dealt with the pandemic.
    Parents know what the COViD scare did to their kids
    They know that their kids are the big losers
    And all of us

    Because we forgot
    That kids should come first

  • Convenient

    The argument that somehow Covid simply culled the herd of the old, obese, and sick is outrageous. The flu total deaths are still counted and if you ever need a bed at hospitals during flu season you’d understand why!
    The effects of the anti vaccine crowd is having going forward is currently seen in strongholds like Florida where major measles outbreaks are taking place with the encouragement of the Florida state government.
    The teaching of the lack of empathy for others who have disabilities, because of inconvenience, is becoming an Iowa calling card.

  • Agreed

    Bettscott is on point.

    States that followed time-honored and proven public health practices experienced less death from COVID than those who chose the path of political expediency.

    Get your COVID and flu shots as advised by your physician. Your doctor knows better than FOX talking heads and RFK, Jr.

  • more verses

    The thought police will quickly cut you off
    Asking you to wear masks how ever they work
    Playing blue vs red
    Even though there was no difference in deaths

    Notice they do not mention anything about our kids or children
    They repeat the mantras of our aging Congress
    Of dysfunctional unions and Lobbies

    Of those who shut down our schools
    Of those who sacrificed the future of our kids

  • I found what's below...

    …and will paste it in. I don’t know anything about the source.

  • Masks

    Below is a multi-year trend of influenza cases in the U.S. by year.

    Number of cases in millions
    2022-2023 31
    2021-2022 9.4
    2019-2020 36
    2018-2019 29
    2017-2018 41
    2016-2017 29
    2015-2016 24
    2014-2015 30

    Notice the dramatic drop in cases in 2021-2022.

    The reason? Masks and social distancing.

    Sound public health practices reduced infection risk for all Americans who used good judgement during a pandemic . . . kids, adults and senior citizens.

    Not just for influenza, but COVID also.

    Science makes a difference . . . for those who can move beyond their self interest to do what is best for the whole of their communities.

  • German statistics

    Bill brought statistics from a German company called Statista. These are estimates of how many people got the flu, not how many died from the flu. The U.S. has an official agency that used to report deaths from the flu, this is the CDC. Try to ask the CDC how many people died from the flu in 21-22.

  • CDC

    CDC stats show a significant decrease of flu activity across the board in 2021/2022 . . .

  • indeed

    Yes Bill, I saw that same CDC document that you refer to. Its purpose is to report flu deaths since 2010 . It is dated “Last Reviewed: February 28, 2024”. Flu deaths are not provided for 2020-2021. It simply states “Estimates are not available for the 2020-2021 flu season due to minimal influenza activity.” The document also mentions that deaths from the flu since 2021 are “preliminary estimates”. I have no idea why it takes them multiple years to finalize the data. We may disagree why they stopped counting flu deaths since COViD, but they did stop counting.

  • One could come away

    from reading all these back and forth comments and have completely forgotten the point of the post, which is that headline writers/editors sometimes really, really, really suck at their job.

    And that flaw can result in the equivalent or near equivalent of wittingly or unwittingly sowing disinformation.

    It happens far more often than most people know. I’ve no doubt I’m a victim of it as well. One can’t read everything.

    And Laura’s secondary point was even then, sometimes the article itself gets the takeaway wrong, and you have the same result.

    Karl, you wasted our time here. Wasn’t the first time. Likely not the last, but have at it if you like. It’s a wonderful feature of the comments section here that commenter’s name comes first.

  • Ha! My bad...

    I blame it on the beer.

    Laura, we need a feature update.

    Or I need less beer.

  • Like the bloggers said in the 2000s

    Don’t feed the trolls.

  • To Fly_Away

    You are right about the point of the post, and right that some headlines are badly-written. As a subscriber to three Iowa newspapers, I see dubious headlines more often in one newspaper than in the other two, and don’t know why.

    And I’m sure that misleading headlines happen more when stories/issues are complicated. A prime example in my mind involved the lawsuit that was filed years ago by the Des Moines Water Works against certain northern Iowa farm drainage districts. The lawsuit was filed because those districts were sending massive farm nutrient pollution to Des Moines.

    When that lawsuit was dismissed, many headlines did a very poor job of stating why. (To be fair, some story content about the dismissal wasn’t accurate either, and subsequent news stories that refer back to the lawsuit are also sometimes wrong.)

    To this day, I’ll bet many Iowans believe that lawsuit was dismissed because the drainage districts were not really sending massive pollution to Des Moines. In fact, the pollution was acknowledged reality and was never even in dispute. The lawsuit was dismissed for an entirely different reason. (If I had a dollar for every time I’ve explained that, I could buy myself a nice dinner:-).