144 F.4th 880
6th Cir.2025Background
- Matthew Warman, a former graduate student at Mount St. Joseph University (MSJU), objected to MSJU’s COVID-19 vaccine mandate on religious and medical grounds, seeking an exemption.
- After requesting an exemption, Warman was detained by two campus police officers for about an hour, during which he was pressured to receive the vaccine and subjected to disparaging remarks about his beliefs.
- Warman alleged ongoing harassment after the incident, including surveillance by officers and referral to the FBI, eventually causing him to withdraw from MSJU and repay benefits.
- Warman filed federal and state claims, including violations of his Fourth Amendment rights (unlawful detention), First Amendment rights (free exercise), Fourteenth Amendment rights (equal protection), and disability discrimination, as well as state tort claims.
- The district court dismissed all federal claims with prejudice and declined supplemental jurisdiction over state claims; Warman appealed this ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Unlawful Detention (Fourth Amendment) | Officers detained Warman without cause, violating his right to be free from seizure. | Detention was not a seizure; officers were acting as concerned veterans, not law enforcement. | Warman plausibly alleged a Fourth Amendment violation; dismissal reversed. |
| State Actor Status (§ 1983) | Campus officers, endowed with state police powers, acted under color of state law. | As private university employees, officers (and MSJPD) are not state actors; MSJPD not subject to suit. | Officers are state actors; MSJPD not sui juris (not subject to suit). |
| Free Exercise (First Amendment) | Vaccine enforcement and denial of exemption burdened his religious exercise rights. | No coercion of religious practice; private university actions not state action. | No free exercise violation; dismissal affirmed. |
| Equal Protection | He was treated differently than other unvaccinated students without rational basis. | No allegations of differential treatment by any specific defendant; actions tied to policy not individual conduct. | No plausible equal protection claim; dismissal affirmed. |
| Disability Discrimination | Denial of accommodation for disabilities violated Rehabilitation Act. | No act of discrimination solely due to disability; Warman withdrew voluntarily before compulsory action was required. | No plausible disability discrimination claim; dismissal affirmed. |
| State Law Claims | Requested reinstatement following partial federal claim reinstatement. | Declined supplemental jurisdiction after federal claims were dismissed. | Dismissal vacated; remanded for reconsideration in light of revived claim. |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for pleading)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard for factual sufficiency)
- Kentucky v. Graham, 473 U.S. 159 (official-capacity suits and entity liability)
- Monell v. Department of Social Services, 436 U.S. 658 (municipal and analogous private entity liability under § 1983)
- West v. Atkins, 487 U.S. 42 (state actor definition under § 1983)
- Wyatt v. Cole, 504 U.S. 158 (immunities in § 1983 actions)
- Richardson v. McKnight, 521 U.S. 399 (qualified immunity for private actors)
- Filarsky v. Delia, 566 U.S. 377 (qualified immunity for private individuals assisting the government)
- DiLuzio v. Village of Yorkville, 796 F.3d 604 (qualified immunity principles)
- United States v. Mendenhall, 446 U.S. 544 (standard for what constitutes a seizure for Fourth Amendment purposes)
- Meriwether v. Hartop, 992 F.3d 492 (standards for granting motion to dismiss under § 1983)
- Bartell v. Lohiser, 215 F.3d 550 (private parties as state actors for § 1983 when performing public functions)
- TriHealth, Inc. v. Bd. of Comm’rs, 430 F.3d 783 (Equal Protection Clause requirements)
- Doe v. Salvation Army in the U.S., 685 F.3d 564 (Rehabilitation Act claim elements)