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United States of America, United States District Court for the Eastern District of Michigan, 4 March 2022, No. 22-cv-10127‎

Case overview

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Country
United States of America
Case ID
No. 22-cv-10127‎
Decision date
4 March 2022
Deciding body (English)
United States District Court for the Eastern District of Michigan
Type of body
Court
Type of Court (material scope)
Civil Court
Type of jurisdiction
Single jurisdiction system
Type of Court (territorial scope)
Local Court
Instance
1st Instance
Area
Vaccination
Further areas addressed
Education
Vulnerability groups
Children
Outcome of the decision
Claim inadmissible or rejected
Link to the full text of the decision
Decision_EN available on www.casetext.com

Case analisys

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
Federal government measure
Measures, actions, remedies claimed
  • Injunctive relief
  • Enjoinment of enforcement
Individual / collective enforcement
Action brought by a specific group of claimants in their own interest for the purpose of injunctive measures or other remedies, including the annulment of administrative decisions, for the protection of a more general collective interest.
Nature of the parties
  • Claimant(s)
    Private collective
  • Defendant(s)
    Public
Type of procedure
Urgency
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.‎

Balancing Fundamental Rights and Fundamental Freedoms

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
Equity
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.‎

Author of the case note
Maíra Tito, Research Assistant, NOVA School of Law, Lisbon
Published by Chiara Naddeo on 17 June 2022

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