related to the black lives matter and police reform movements (such as "i can't breathe") attracted popularity amidst nationwide protests following the murder of george floyd. in june 2020, the united states postal inspection service temporarily seized a shipment of face masks with the slogan "stop killing black people", ordered by the movement for black lives for distribution to those attending demonstrations in minneapolis, new york city, st. louis, and washington d.c.. the service stated that there "were indications that they contained non-mailable matter." citing these concerns over racial profiling, lincoln county, oregon (whose population is 95% white) initially announced that it would provide an exemption for people of color from the county's mask mandate. however, following criticism, the county backtracked on june 24. officials stated that "the expressions of racism regarding the exception has created a ripple of fear throughout our communities of color. the very policy meant to protect them, is now making them a target for further discrimination and harassment." confrontations over mask requirements there have been incidents of violent confrontations and assaults over disagreements about the masking policies of states and private businesses. numerous reports were made of retail patrons assaulting employees at retail store's over disagreements about the store's masking policies. a man was arrested in october 2020 for threatening to kidnap and murder the mayor of wichita, kansas over the city's mask mandate. by september 2020, over 170 transit workers in new york city had reported being assaulted or harassed for asking passengers to wear face masks, including a 62-year-old man who was knocked unconscious on his route through east new york, brooklyn, prompting officials to implement a $50 fine for riders who refused to wear a face mask. there have also been instances of assault against persons who refused to comply with masking policies. in key largo, a bus driver was arrested for swinging a metal rod at a passenger who lowered his mask to make a call on his cell phone. appearance of vulnerability refusal to wear a mask in public may be driven by a fear of being seen as vulnerable and fearful of covid-19. in a may 2020 survey of 2,459 americans conducted by valerio capraro of middlesex university london and hélène barcelo of the mathematical sciences research institute, it was found that men surveyed were more likely to display negative stigmas towards wearing masks in public, including being more likely to agree that it was "uncool", "shameful", and a "sign of weakness". capraro noted that these stigmas were more prevalent among residents of areas that had mandated the wearing of face masks. reporting on the study, ben boskovich of esquire wrote that "the phrase toxic masculinity gets thrown around a lot, sometimes more than necessary, if we're being honest. but this thing, this reality, that men are too blinded by their own inherent privilege to acknowledge their vulnerabilities, to admit they're wrong, to let go of the steering wheel, is as real as the president's hats are red.". attempts to incentivize usage before eventually mandating them across all properties nationwide, and nevada announced its statewide order, caesars entertainment attempted a promotion at its casinos in las vegas, where rewards members could win $20 credits if spotted wearing a mask on the casino floor. mask use and policies by state variable message sign on the garden state parkway in new jersey, informing drivers that face coverings are required in service areas woman in ohio wearing a neck gaiter as a protective face covering. high school field hockey players in ohio with and without masks. by mid-november 2020, 37 states had some sort of health order requiring the wearing of face masks or a similar non-medical face covering when in public spaces or specific types of establishments. absent a state-level mandate, some municipalities and counties have instituted their own mandates via localized by-laws. these orders usually have exceptions for younger children, as well as those with medical conditions (such as breathing problems) or disabilities that would make it difficult to wear a mask. they are also usually considered an exception to prohibitions on the wearing of masks in public for the purpose of identity concealment, such as general anti-mask laws, and restrictions on wearing masks while carrying a concealed firearm. some states, such as louisiana, oregon, and washington, at first only mandated the wearing of masks by the public-facing employees of businesses, before mandating they be used by the general public as well. based on a study published in october 2022, mandatory face mask and stay-at-home policies' purposes were lack of consistency with infection rates and fatality rates during the united states covid-19 pandemic period until august 2020, the period only non-pharmaceutical interventions available. states with mandatory face mask policies seem did not shown preventive effects on the incidence or average daily cases during mandatory stay-at-home order periods. there was a decrease in fatality rate when normalized to population density through mandatory face mask and stay-at-home orders. however, there were no significant differences in incidence rate, average daily new cases, fatality rate, and mortality rates among the states with or without mandatory face mask or/and stay-at-home groups. the potential reasons listed were limited in enforcement on mandatory face mask and stay-at-home, limited in mask usage adherence, and lack of mask-wearing protocols and access to higher-quality masks. enforcement and challenges violations of mandatory mask orders have often classified as a misdemeanor offence, with some states threatening fines for individuals who do not comply. some states expressly require businesses to enforce mask mandates, with failure to do so also punishable by fines, and in some cases, being ordered to temporarily close, or have their business license revoked. whether these mandates are actually enforced may vary; some sheriffs in california, nevada, north carolina, and washington state pledged that they would not enforce the orders; one such sheriff in lewis county, washington, announced to a crowd outside a church, "don't be a sheep". by contrast, governor of california gavin newsom threatened to withhold covid-19 relief funding from counties that do not sufficiently enforce state health orders, including its mask mandate. in late-june 2020, governor of south carolina henry mcmaster argued that the inability to effectively enforce such an order influenced his decision to not implement an order at that time, stating that "there's no power on earth that can follow everyone in the state around to be sure that they are following the rules." however, on july 29, mcmaster reversed his prior stance and issued a statewide mandate, as part of an order taking affect august 3 that also allowed more businesses to resume operations. on october 2, the michigan supreme court unanimously ruled that governor gretchen whitmer had violated the state emergency management act of 1976 by redeclaring a state of emergency to bypass the republican-controlled legislature after it declined to renew it. in a split decision, they ruled that the emergency powers of governor act of 1945 was unconstitutional because it violated the nondelegation doctrine. governor whitmer has argued that the decision was still subject to a 21-day reconsideration period, during which the orders still stand, and later accused the court of undermining her efforts to control the pandemic. on october 4, michigan attorney general dana nessel stated that she would stop enforcing covid-19-related executive orders. on october 12, the court denied a notion requested by governor whitmer for a transition period, thereby voiding all executive orders issued pursuant to the claimed state of emergency. the state department of health and human services (mdhhs) had already begun to issue its own orders to supplant whitmer's voided orders, under powers that give its director the authority to "establish procedures" and restrict gatherings during an epidemic. in turn, the mdhhs was sued by a chiropractor (one which had faced warnings from local officials for defying the mask mandate), claiming it did not have the authority to mandate masks. in wisconsin, governor tony evers similarly re-declared a public health emergency (which is similarly limited to 60 days without legislative approval) to extend its mask mandate beyond its original period (which began august 1). it was challenged in a state court by the wisconsin institute for law and liberty, who requested a temporary injunction. judge michael waterman ruled in favor of governor evers, stating that "the 60-day limit provides an important check against run-away executive power, but it does not prevent the governor from issuing a new executive order when the emergency conditions continue to exist." when cook county, illinois passed a mandate requiring patrons at restaurants, gyms and other retail stores to show proof of vaccination, one of the county's local villages, orland park, refused to enforce it. keith pekau, mayor of the village, remained defiant during the pandemic, even suing illinois’ governor in federal court over business lockdowns. political stances a mask compliance officer at a baseball park in florida. opponents of mask mandates have sometimes argued that they are unconstitutional; the american bar association cited that there was precedent under the tenth amendment (which states that any powers not granted to the federal government via the constitution are reserved to states) that state governments "have the primary authority to control the spread of dangerous diseases within their jurisdictions." jacobson v. massachusetts has also been cited as case law supporting mask orders; it found that the use of police power by states to enforce health orders designed to maintain the safety of their communities (such as, in this case, mandatory vaccinations for smallpox), did not violate individual liberties under the fourteenth amendment. in june 2020, the hill noted that democratic-led and coastal states had been more likely to have implemented or considered such mandates over republican-led states (especially in the conservative south)—which have cited desires to preserve individual liberties, and, in some cases, also took steps to overrule local health orders that are stricter than those imposed by the state (including mask mandates). not all republican-led states refused to do so, however, with noted early examples including maryland and massachusetts. following a major spike in mid-june attributed to the rushed lifting of mitigations around the memorial day weekend, arizona and texas began to backpedal on their outright prohibition of local orders on the wearing of masks, and governor of texas greg abbott then issued a statewide mandate on july 2. on july 15, governor of georgia brian kemp signed an executive order to prohibit any county or municipality from enacting or enforcing a health order requiring the wearing of masks in public spaces. he also filed a lawsuit against mayor of atlanta keisha lance bottoms and her city council over a local health order requiring masks, and voluntarily rolling back to "phase 1" guidelines (discouraging dine-in restaurants), asserting that she "does not have the legal authority to modify, change or ignore governor kemp's executive orders." on august 13, however, kemp dropped the lawsuit, and announced the next day that localized mask mandates would be allowed if certain "health metrics" and other guidelines are met, and requiring business owners to consent if the mandate is to apply to businesses. in kansas, a july 2020 mask mandate by democratic governor laura kelly included the ability for counties to opt out if they (per consultation with health officials) assert that it is not medically necessary; the provision was described as a "bipartisan compromise" to gain support from the state's republican-majority government. by july 9, 90 of kansas's 105 counties had opted out, while several cities in counties that did opt out, such as manhattan, wichita, and winfield, would enact municipal mandates. out of a sample of counties, 15 counties that chose to enforce the order were shown to have a reduced rate of new cases than those which opted out. research released in october 2020 by the university of kansas found that these trends had continued in the, by then, 21 counties that implemented the order. the mayor of dodge city, kansas resigned from office in december 2020 after facing violent threats over her support of a local mask mandate. governor of south dakota kristi noem questioned studies and research that support the use of face masks, claiming that they have produced "very mixed" outcomes, and arguing that "the science has not proven what's effective and what isn't and what type of mask. we have to