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Responding to historical arguments about the decline of local control in American public schools, this study explores if and how school districts are limited because of tension between two concepts of democracy: participatory & deliberative. This study used case studies of library censorship over the inclusion of books with LGBTQIA+ content in 2008 and 2019 to see if either followed the guidance of Pico (1982), both in terms of the categorizations in Justice Brennan’s plurality opinion and in combining participatory and deliberative democracy. Our findings demonstrate that district practices have diverged from the ideals in democratic theory and legal decisions. Therefore we posit an additional reason for the decline of local control: the divergence of theory and practice.