618 F.Supp.3d 72
N.D.N.Y.2022Background
- Plaintiffs are two Security Services Assistants at SUNY hospitals who challenge New York DOH’s emergency COVID-19 Vaccine Mandate requiring covered healthcare personnel to be fully vaccinated (adopted Aug. 26, 2021); several other original plaintiffs became moot.
- The mandate applied to hospital personnel and required vaccination by set deadlines unless an exemption applied; DOH separately authorized routine testing options in some school settings.
- Plaintiffs allege vaccination carries unknown/serious risks and that they would lose their jobs absent vaccination; they assert willingness to comply with masking and testing.
- Plaintiffs sued under 42 U.S.C. § 1983, asserting Fourteenth Amendment claims: Equal Protection (healthcare workers treated differently than teachers who may test) and substantive due process (liberty to refuse medical treatment and unconstitutional conditions).
- The district court previously denied a preliminary injunction; on Defendants’ Rule 12(b)(6) motion the court dismissed the Complaint and dismissed moot plaintiffs, concluding the mandate survives rational-basis review and does not violate substantive due process or the unconstitutional-conditions doctrine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Equal Protection — differential treatment of healthcare workers vs teachers | Mandate irrationally denies testing alternative available to teachers; no rational basis for distinction | Classification furthers legitimate public-health aims; many conceivable rational bases exist (vulnerable patients, outbreak risk, staffing capacity) | Dismissed — classification reviewed under rational basis; plaintiffs failed to negate all conceivable rational bases |
| Substantive Due Process — right to refuse unwanted medical treatment | Mandate infringes liberty to refuse medical treatment; loss of job is a severe consequence that burdens the right | Right to refuse vaccination is not a fundamental right here; mandate is rationally related to public-health objectives | Dismissed — no fundamental right implicated; rational-basis review applies and is satisfied |
| Unconstitutional Conditions — conditioning employment on vaccination | Employment conditioned on relinquishing constitutional right to refuse treatment; coercive penalty | Plaintiffs haven’t shown the State couldn’t directly impose vaccination; no predicate showing the right is fundamental or that coercion was unconstitutional | Dismissed — plaintiffs failed to allege the State couldn’t directly mandate vaccination; no viable unconstitutional-conditions claim |
| Mootness / Standing for other plaintiffs | (N/A) | Several original plaintiffs retired or were vaccinated and returned to work | Claims of seven other plaintiffs dismissed as moot; case closed |
Key Cases Cited
- Jacobson v. Massachusetts, 197 U.S. 11 (upholding state vaccination law during public‑health emergency)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for pleadings)
- Ashcroft v. Iqbal, 556 U.S. 662 (legal conclusions not entitled to assumption of truth)
- City of Cleburne v. Cleburne Living Ctr., 473 U.S. 432 (classifications not suspect unless so designated)
- FCC v. Beach Commc’ns, Inc., 508 U.S. 307 (rational‑basis review: any conceivable rational basis suffices)
- Lehnhausen v. Lake Shore Auto Parts Co., 410 U.S. 356 (burden to negative every conceivable basis)
- Cruzan v. Director, Mo. Dep’t of Health, 497 U.S. 261 (recognizing liberty interest in refusing unwanted medical treatment)
- Koontz v. St. Johns River Water Mgmt. Dist., 570 U.S. 595 (unconstitutional‑conditions doctrine principles)
- We the Patriots USA, Inc. v. Hochul, 17 F.4th 266 (vaccination requirements valid exercise of public‑health power)
- Kane v. de Blasio, 19 F.4th 152 (upholding vaccine mandate for teachers under rational basis)
- Sensational Smiles, LLC v. Mullen, 793 F.3d 281 (courts should not second‑guess public‑health policy choices)