United States of America, United States District Court for the Eastern District of Michigan, 4 March 2022, No. 22-cv-10127
Case overview
Country
Case ID
Decision date
Deciding body (English)
Type of body
Type of Court (material scope)
Type of jurisdiction
Type of Court (territorial scope)
Instance
Area
Further areas addressed
Vulnerability groups
Outcome of the decision
Link to the full text of the decision
General Summary
The plaintiffs, four Michigan school districts, filed an action against the Department of Health and Human Services regarding the recently implemented criteria to receive grants from the Head Start Program. The program aimed “to break the cycle of poverty through the provision of comprehensive health, education, parental involvement, nutritional, social, and other services to low-income preschool children and their families.” On January 31, 2022, a new regulation stated that in order to receive funding, “participating facilities must ensure that their staff, contractors, and volunteers, unless exempt for medical or religious reasons, are vaccinated against COVID-19.” The school districts presented the case seeking a declaration that the new rule was unlawful and an order to enjoin its enforcement in their districts. The Court analyzed the arguments of both parties and denied the preliminary injunction. It stated that although “the plaintiffs have shown a likelihood of irreparable harm, Plaintiffs are not likely to succeed on the merits of their claims, there is a likelihood of substantial harm to others if an injunction issues, and that the public interest strongly weighs against ruling in Plaintiffs' favor.”
Facts of the case
Head Start is a federal discretionary grant program that promotes school readiness in low-income children through age five. In November 2021, the Secretary announced that, in order to receive Head Start funding, participating facilities must ensure that their staff, contractors, and volunteers - unless exempt for medical or religious reasons - are vaccinated against COVID-19. The Rule took effect on January 31, 2022. Four school districts filed an action seeking preliminary injunction and enjoinment of enforcement of the rule, however the Court rejected the claim.
Type of measure challenged
Measures, actions, remedies claimed
- Injunctive relief
- Enjoinment of enforcement
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 likelihood of success of the measure, the Court reasoned that the Secretary of Health and Human Services had statutory authority to issue the rule, that it did not exceed its authority, and that Supreme Court case law supported those findings;
2) Regarding the content of the rule, the Court stated that it was not arbitrary and capricious and that the agency action was reasonable and reasonably explained;
3) Regarding the chance of irreparable harm, the Court admitted that students and their families could be harmed by a lack of conditions that are only possible through the grant;
4) Regarding the chance of harm to others, the Court stated that the possibility of the spread of the coronavirus in the school environment was a fact that weighed in favor of the government.
Conclusions of the deciding body
The Court found that, while plaintiffs had shown a likelihood of irreparable harm, plaintiffs were not likely to succeed on the merits of their claims. It concluded that there was a likelihood of substantial harm to others if an injunction were issued, and that the public interest strongly weighed against a ruling in the plaintiffs' favor. Accordingly, the balance of factors together weighed against an injunction and the Court therefore rejected the claim.
Fundamental Right(s) involved
- Right to education
- Right to good administration
Rights and freedoms specifically identified as (possibly) conflicting with the right to health
- Health v. right to education
- Health v. right to good administration
General principle applied
Balancing techniques and principles (proportionality, reasonableness, others)
The Court balanced the factors prescribed by law concerning injunctive relief. It found that, while plaintiffs had shown a likelihood of irreparable harm, they were not likely to succeed on the merits of their claims. It concluded that there was a likelihood of substantial harm to others if an injunction were issued, and that the public interest strongly weighed against ruling in the plaintiffs' favor. Accordingly, the balance of factors together weighed against an injunction.
