Church v. Biden, Civil Action No. 2021-2815

Plaintiffs: 18 federal civilian employees and 2 active-duty Marines challenge COVID-19 vaccine mandates for federal employees (Exec. Order 14043) and DoD/Marine Corps vaccine directives.
Nearly all plaintiffs sought religious exemptions; one civilian (Hallfrisch) was granted an exemption; the others have pending requests; two Marines had initial denials but appealed and received temporary administrative exemptions.
Plaintiffs moved for emergency relief (TRO/PI) to enjoin enforcement of the mandates and to require religious accommodations or void enforcement actions.
Defendants represented that no employee/service member with a pending exemption request will be disciplined while the request/appeal is pending and described administrative processes available before termination/discipline.
Court: denied TRO/PI because plaintiffs’ claims are not ripe (contingent on pending administrative determinations), plaintiffs failed to show certain irreparable harm, and the balance of harms/public interest (public health, military readiness, and orderly administration) weigh against injunctive relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ripeness / Justiciability	Mandates already burden religious freedom and RFRA rights and are reviewable now	Claims speculative because exemption requests/appeals are pending; no final agency action; no imminent injury	Denied — claims not constitutionally or prudentially ripe; adjudication premature while administrative remedies pending
Irreparable Harm	Forced vaccination or termination would cause irreparable constitutional and statutory injury and employment loss	No imminent irreparable harm: plaintiffs retain jobs while exemptions pending; employment losses remedied by later relief	Denied — plaintiffs failed to show certain, imminent, irreparable harm; speculative injury insufficient
Military deference / Exhaustion	Military plaintiffs need immediate relief because mandates affect service members’ rights	Courts should defer to military expertise and require exhaustion of intramilitary remedies before judicial intervention	Denied — military claims not justiciable now; exhaustion and deference principles weigh against emergency relief
Balance of harms & public interest	Plaintiffs’ employment and religious interests outweigh harms from continued mandates	Public interest in stopping COVID-19 spread, protecting workforce and military readiness favors enforcement	Denied — public interest and military readiness outweigh plaintiffs’ speculative harms

Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (2008) (standard for preliminary injunction; movant must show likelihood of success and irreparable harm)
Mazurek v. Armstrong, 520 U.S. 968 (1997) (preliminary injunction is extraordinary relief)
Elrod v. Burns, 427 U.S. 347 (1976) (loss of First Amendment freedoms may presumptively constitute irreparable harm)
Sampson v. Murray, 415 U.S. 61 (1974) (loss of employment not ordinarily irreparable absent extraordinary circumstances)
Nat’l Park Hosp. Ass’n v. Dep’t of Interior, 538 U.S. 803 (2003) (prudential ripeness factors: fitness and hardship)
Abbott Labs. v. Gardner, 387 U.S. 136 (1967) (ripeness framework for agency action)
Chaplaincy of Full Gospel Churches v. England, 454 F.3d 290 (D.C. Cir. 2006) (preliminary injunction standard in D.C. Circuit)
Davis v. Pension Benefit Guar. Corp., 571 F.3d 1288 (D.C. Cir. 2009) (sliding-scale approach to injunction factors discussed)
Bois v. Marsh, 801 F.2d 462 (D.C. Cir. 1986) (courts must hesitate before intervening in military personnel matters)
Orloff v. Willoughby, 345 U.S. 83 (1953) (judicial restraint regarding internal military matters)
Roe v. Dep’t of Def., 947 F.3d 207 (4th Cir. 2020) (military plaintiffs generally must exhaust administrative remedies before suing)