The possibility of an influenza pandemic occurring within the next two decades is very real; the role of local governments in comprehensive preparation for this global threat is crucial. The federal government has provided broad guidelines for state and local officials who are ultimately responsible for emergency response and lifesaving services, vaccination and antiviral use, and the provision of other critical support. Much of this influenza pandemic preparedness has occurred under conditions of uncertainty, and these government actions may have unprecedented legal and ethical implications. This study evaluates the pandemic influenza policies of eight large U.S. cities to determine how Department of Health and Human Services recommendations with ethical and legal implications have been addressed. The authors find that several important aspects of these guidelines are vague in many plans, and input from key stakeholders is inadequate.