Background
Former employees of the Washington Department of Children, Youth and Families were separated from employment after their requests for religious accommodations to a state COVID-19 vaccination mandate were denied. The employees sued the agency and three officials under Section one thousand nine hundred eighty-three, alleging violations of free exercise, equal protection, and procedural due process rights. The district court dismissed the claims for failure to state a claim, and the employees appealed.
The court’s reasoning
The Ninth Circuit reviewed the complaint de novo and concluded that the employees failed to establish personal involvement by the officials under Section one thousand nine hundred eighty-three. The court found that the internal communications cited by the employees did not demonstrate religious animus but rather an intent to comply with statutory obligations. Furthermore, the court held that claims for prospective injunctive relief were barred by the Eleventh Amendment because the vaccination mandate had been rescinded months before the suit was filed, leaving no ongoing violation of federal law. The court also affirmed the denial of leave to amend, noting that the first amended complaint failed to cure the identified defects.
What it means going forward
The ruling reinforces the high pleading standard for establishing personal involvement in Section one thousand nine hundred eighty-three cases and limits the ability to seek prospective injunctive relief against state officials when the challenged policy is no longer in effect.