Jackson v. Noem, 132 F.4th 790

In 2021, the Department of Defense and the Coast Guard required all servicemembers to receive a COVID-19 vaccination.
Plaintiffs (Jackson, Stone, Marcenelle), Coast Guard servicemembers, refused the vaccine for religious reasons and were denied accommodation.
Plaintiffs sued, alleging the mandate violated the Religious Freedom Restoration Act (RFRA), the First Amendment, and the Administrative Procedure Act (APA).
During litigation, the vaccine mandates were rescinded and involuntary separations stopped.
The district court dismissed the case as moot, finding that the challenged policy no longer existed and no remedy could be granted.
Plaintiffs appealed, asserting ongoing harms due to their unvaccinated status and a lack of protective policies from the Coast Guard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness due to rescinded mandate	Ongoing harms exist; rescission doesn't prevent future discrimination.	Mandate rescinded; no continuing harm; case is moot.	Not moot; possible for court to grant effectual relief.
Injunctive relief against future discrimination	Coast Guard hasn't barred discrimination based on vaccination status.	No evidence of continued discrimination; concerns are hypothetical.	Plausibly alleged ongoing harm; injunction may be warranted.
Relief under RFRA, First Amendment, and APA	Mandate and accommodation process violated core rights; still at risk.	All policies challenged have been rescinded; injury ended.	Case should proceed; live controversy remains.
Injuries and redressability post-rescission	Service reputation remains harmed, affecting promotions, etc.	No actual injury since rescission; promotion records do not support.	Reputation injury could be remedied by declaratory relief.

Chafin v. Chafin, 568 U.S. 165 (case is not moot where parties have a concrete interest, however small)
Lewis v. Continental Bank Corp., 494 U.S. 472 (Article III requires actual ongoing controversy; mootness standards)
Spell v. Edwards, 962 F.3d 175 (once challenged law is repealed, there is nothing injuring the plaintiff)