Klaassen v. Indiana University (No. 1:21-CV-238 DRL, N.D. Ind.), was a 2021 United States federal court case in which students attending Indiana University challenged the institution's COVID-19 vaccine mandate set to go into effect in September 2021. A motion for preliminary injunction was denied by Judge Damon R. Leichty on July 18, 2021. On August 2, 2021, the United States Court of Appeals for the Seventh Circuit also denied a motion to enjoin the mandate while Leichty's ruling was appealed. [1] On August 12, 2021, Justice Amy Coney Barrett denied relief to the petitioners, allowing the vaccination mandate to go into effect. [2] The case is named for lead plaintiff Ryan Klassen of Noble County, Indiana. [3]
In May 2021, Indiana University announced that COVID-19 vaccination would be mandatory for the fall 2021 semester, except for students who received a medical or religious exemption from vaccination. Students ineligible for an exemption would either need to be vaccinated, or would be excluded from the university, while students who received exemptions would need to wear masks, undergo periodic testing for COVID-19, and engage in certain social distancing activities. Eight students filed a lawsuit objecting to this requirement. Most of these students had either already received religious exemptions from vaccination, or were eligible for such exemptions, but objected to the requirement that they be singled out for mask-wearing and COVID-19 testing if they continued to be unvaccinated.
The opinion of the district court judge denying preliminary injunction was 101 pages, unusually lengthy for that stage of the case. Judge Leichty addressed at length the question of whether the 1905 United States Supreme Court case of Jacobson v. Massachusetts was still the appropriate legal precedent to follow, concluding that it was. Judge Leichty further examined the objection that the vaccines being mandated were only available under Emergency Use Authorization, and found this to be no impediment to the mandates on the basis that the Food and Drug Administration had employed an "EUA-plus" degree of examination, providing far more stringent requirements for issuance of the EUA than were required by law. The Seventh Circuit decision did not discuss the EUA status of the vaccines, but noted that the case was "easier than Jacobson for the University" because of the broader exemptions provided by the university, and because the mandate was directed not to the general public, but only to university students and staff.
The case was finally dismissed on February 22, 2022. Notably, all of the judges who considered the case were Republican appointees, including Judge Leichty on the district court, Judges Easterbrook, Scudder, and Kirsch on the Seventh Circuit panel, and Justice Barrett on the Supreme Court.
Frank Hoover Easterbrook is an American lawyer and jurist who has served as a United States circuit judge of the U.S. Court of Appeals for the Seventh Circuit since 1985. He was the Seventh Circuit's chief judge from 2006 to 2013.
Liberty Counsel is a 501(c)(3) tax-exempt religious liberty organization that engages in litigation related to evangelical Christian values. Liberty Counsel was founded in 1989 by its chairman Mathew Staver and its president Anita L. Staver, who are attorneys and married to each other. The Southern Poverty Law Center has listed Liberty Counsel as an anti-LGBT hate group, a designation the group has disputed. The group is a Christian ministry.
Diane Pamela Wood is an American attorney who serves as the director of the American Law Institute, a senior circuit judge of the United States Court of Appeals for the Seventh Circuit, and a senior lecturer at the University of Chicago Law School.
Ransey Guy Cole Jr. is a senior United States circuit judge of the United States Court of Appeals for the Sixth Circuit.
Jacobson v. Massachusetts, 197 U.S. 11 (1905), was a United States Supreme Court case in which the Court upheld the authority of states to enforce compulsory vaccination laws. The Court's decision articulated the view that individual liberty is not absolute and is subject to the police power of the state. Jacobson has been invoked in numerous other Supreme Court cases as an example of a baseline exercise of the police power.
David Norman Hurd is a United States district judge of the United States District Court for the Northern District of New York.
Earl Leroy Yeakel III, also known as Lee Yeakel, is a former United States district judge of the United States District Court for the Western District of Texas.
Reed Charles O'Connor is a United States district judge of the United States District Court for the Northern District of Texas. He was nominated by President George W. Bush in 2007.
The Washington State Department of Health is a state agency of Washington. It is headquartered in Olympia, Washington. The agency was created by the state legislature in May 1989 after splitting from the Washington State Department of Social and Health Services.
Amy Vivian Coney Barrett is an American lawyer and jurist who serves as an associate justice of the Supreme Court of the United States. The fifth woman to serve on the court, she was nominated by President Donald Trump and has served since October 27, 2020. Barrett was a U.S. circuit judge on the U.S. Court of Appeals for the Seventh Circuit from 2017 to 2020.
Terry Alvin Doughty is the Chief United States district judge of the United States District Court for the Western District of Louisiana. Nominated by President Donald Trump, Doughty served as a judge on the Fifth Judicial District Court in Louisiana from 2009 to 2018.
Zucht v. King, 260 U.S. 174 (1922), was a landmark decision by the Supreme Court of the United States in which the Court held, 9–0, that public schools could constitutionally exclude unvaccinated students from attending, even if there was not an ongoing outbreak. In the case, the school district of San Antonio, Texas enacted an ordinance that prohibited any child from attending a school within the district unless they had been vaccinated against smallpox. One parent of a student who had been excluded, Rosalyn Zucht, sued on the basis that there was not a public health emergency. Justice Louis Brandeis wrote for the unanimous court that requiring students to be vaccinated was a justified use of "police power" to maintain public health and safety.
Vaccination policy of the United States is the subset of U.S. federal health policy that deals with immunization against infectious disease. It is decided at various levels of the government, including the individual states. This policy has been developed over the approximately two centuries since the invention of vaccination with the purpose of eradicating disease from the U.S. population, or creating a herd immunity. Policies intended to encourage vaccination impact numerous areas of law, including regulation of vaccine safety, funding of vaccination programs, vaccine mandates, adverse event reporting requirements, and compensation for injuries asserted to be associated with vaccination.
Horvath v. City of Leander, No. 18-51011 is a legal case decided in 2020 by the United States Court of Appeals for the Fifth Circuit, holding that an employer may require employees to receive vaccinations, so long as the employer makes reasonable accommodations to religious objections, even if the accommodations offered are not ideal for the employee.
The COVID-19 pandemic reached the U.S. state of Indiana on March 5, 2020, and was confirmed on March 6. As of July 12, 2021, the Indiana State Department of Health (ISDH) had confirmed 757,904 cases in the state and 13,496 deaths. As of July 3, 2020, all 92 counties had reported at least 10 cases with Pike County being the last to surpass this threshold.
Phillips v. City of New York, 775 F.3d 538, cert. denied, 136 S. Ct. 104 (2015), was a 2015 decision of the United States Court of Appeals for the Second Circuit addressing vaccination mandates and exemptions from them in New York City. The court concluded that it was within the constitutional police power of the state to mandate vaccination, and that religious exemptions were not constitutionally required. Therefore, even though the state did permit religious exemptions, it was free to provide them with limitations including the exclusion of exempted children from school during an outbreak of the disease, and requiring applicants to demonstrate the sincerity of their religious objection in order to receive an exemption.
Caviezel v. Great Neck Public Schools, 500 Fed. Appx. 16 (2012), is a decision of the United States Court of Appeals for the Second Circuit upholding the denial of a religious exemption to mandatory vaccination sought by a parent who claimed to adhere to a non-denominational religious view without a formal doctrine.
Over the course of the COVID-19 pandemic, COVID-19 vaccine mandates have been enacted by numerous states and municipalities in the United States, and also by private entities. In September 2021, President Joe Biden announced that the federal government would take steps to mandate COVID-19 vaccination for certain entities under the authority of the federal government or federal agencies. Most federal mandates thus imposed were either overturned through litigation, or withdrawn by the administration, although a mandate on health care workers in institutions receiving Medicare and Medicaid funds was upheld. All federal mandates were lifted when the national emergency was declared to have ended in May 2023. A small number of states have gone in the opposite direction, through executive orders or legislation designed to limit vaccination mandates.
The Biden administration COVID-19 action plan, also called the Path out of the Pandemic, is a substantial increase in the use of vaccination mandates as part of the U.S. federal government response to the COVID-19 pandemic announced by President Joe Biden on September 9, 2021, to be carried out by officials in the Biden administration. The plan included various announced prospective efforts, as well as the issuance of several executive orders.
National Federation of Independent Business v. Department of Labor, Occupational Safety and Health Administration, 595 U.S. ___ (2022), is a Supreme Court of the United States case before the Court on an application for a stay of the Occupational Safety and Health Administration's COVID-19 vaccination or test mandate. On January 13, 2022, the Supreme Court ordered a stay of the mandate.