United States of America, United States District Court for the District of Massachusetts, 10 March 2022, N. 22-10242-RGS
Case overview
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Link to the full text of the decision
General Summary
The Plaintiffs, employees of the Woods Hole, Martha's Vineyard, and Nantucket Steamship Authority, sought preliminary injunctive relief from the Authority's policy mandating vaccination against COVID-19 as a condition of their continued employment. The Authority's policy, according to plaintiffs, violated their statutory and constitutional rights. Most of the plaintiffs sought religious exemptions from the vaccination Policy. After a review of the plaintiffs' requests, which included the completion of a comprehensive questionnaire and a face-to-face interview, the Authority rejected the accommodation requests as imposing an undue hardship on day-to-day operations.
On February 11, 2022, the plaintiffs filed an action in Barnstable Superior Court seeking injunctive and declaratory relief. The Authority then removed the case to the federal district court. Plaintiffs renewed their motion for preliminary injunctive relief. After analyzing the reasoning of the parties, the Court rejected the plaintiffs' request for injunctive relief.
Facts of the case
Woods Hole, Martha's Vineyard, and Nantucket Steamship Authority was created by the Massachusetts Legislature in 1960 to provide ferry service to the islands of Martha's Vineyard and Nantucket, and it regularly "services members from all walks of life, including young children, elderly individuals, and the immunocompromised."
On January 3, 2022, the Authority issued a COVID-19 Vaccination Verification Policy covering all employees. The Policy stated that "all employees must receive at least one (1) dose of a COVID-19 vaccine by January 5, 2022 and must be fully vaccinated by February 16, 2022.” Employees who refused the vaccine would be subject to progressive disciplinary steps, up to and including termination.
Most of the plaintiffs sought religious exemptions from the vaccination Policy. After a review of the plaintiffs' requests, which included the completion of a comprehensive questionnaire and a face-to-face interview, the Authority rejected their accommodation requests as imposing an undue hardship on day-to-day operations. More specifically, the Authority found that because of plaintiffs' public-facing roles, the requested exemptions would "unreasonably risk" the health and safety of fellow employees, customers, vendors, and the plaintiffs themselves, and thereby "undermine public trust and confidence in the safety of the Authority's facilities and vessels."
Type of measure challenged
Measures, actions, remedies claimed
Individual / collective enforcement
Nature of the parties
Claimant(s)
Private collectiveDefendant(s)
Public
Type of procedure
Reasoning of the deciding body
The Court analyzed the request for injunctive relief and reasoned that:
1) Regarding the alleged violation of religious rights, there was not any proof that the Authority’s vaccination mandate restrained plaintiffs from practising worshipping rituals nor did it impose a burden to some religions more than to others;
2) Regarding the alleged violation of privacy, personal autonomy and personal identity, there was not a violation of those rights since the mandate was a condition to employment with the Authority and not a physically enforceable measure.
The Court cited case law which stated that the Government does not have an obligation to exempt citizens from vaccination based on religious beliefs. It also stated that the Supreme Court does not recongnize mandatory vaccination as a violation of privacy or fundamental rights, and that the "general liberty interest in refusing medical treatment" acknowledged by the Supreme Court was not “a fundamental liberty interest.” Finally, it argued that “the public interest in safely accessing ferry service to Nantucket Island and Martha's Vineyard without fear of contracting COVID-19 from the Authority's unvaccinated employees is profound.”
Conclusions of the deciding body
The Court rejected the motion for injunctive relief.
Fundamental Right(s) involved
- Freedom of religion
- Right to bodily integrity
- Right to privacy
Fundamental Right(s) instruments (constitutional provisions, international conventions and treaties)
- Right to religious worship, Art. 2, Massachusetts Declaration of Rights
- Right to free religious exercise, First Amendment, United States Constitution
- Right to be free of religious discrimination, Mass. Gen. Laws, c. 151B, § 4
- Rights to privacy, personal autonomy, and personal identity, Fourteenth Amendment
Rights and freedoms specifically identified as (possibly) conflicting with the right to health
- Health v. freedom of religion
- Health v. right to privacy (private and family life)
- Health v. right to bodily integrity
Balancing techniques and principles (proportionality, reasonableness, others)
The Court cited precedents from the Supreme Court and other case law to balance the conflicting rights. It therefore concluded that a violation of fundamental rights had not occurred, in the terms interpreted by the Supreme Court and other national Courts.
