1. 57. Resurrection School v. Hertel, No. 20-2256 (6th Cir. Aug. 23, 2021).
2. 25. Letter from Miguel Cardona, Secretary of U.S. Department of Education, to Governor DeSantis and Commissioner Corcoran, Florida (Aug. 13, 2021), available at .
3. 56. See Midwest Institute of Health, PLLC v. Whitmer, 958 N.W.2d 1 (Mich. 2020) (limiting the Governor’s authority to declare emergencies under the Emergency Management Act).
4. 31. U.S. Department of Health and Human Services, Public Readiness and Emergency Preparedness Act (last updated Aug. 3, 2021), available at (last visited October 29, 2021).
5. 18. Schnell, M. , “Indiana Governor Breaks with GOP Peers, Allows Local Mask Mandates,” The Hill, Aug. 16, 2021, available at (last visited Aug. 19, 2021).