Background
Forty-nine former employees of the Washington Department of Corrections sued two officials for wrongful termination after refusing to comply with a COVID-19 vaccine mandate. The plaintiffs alleged violations of the Free Exercise Clause, the Due Process Clause, and the Equal Protection Clause under Section nineteen hundred and eighty-three of Title twenty-eight of the United States Code. The district court dismissed the federal claims with prejudice and denied leave to amend.
The court’s reasoning
The court reviewed the dismissal de novo and found the district court did not err. The plaintiffs failed to state a claim against the defendants in their official capacity because they sought redress for past harms rather than prospective injunctive relief. Regarding claims against the defendants in their individual capacity, qualified immunity barred the suit because the plaintiffs did not plead facts showing a violation of a clearly established right. The court noted that the facts did not plausibly support an inference of religious discrimination or personal animus. The equal protection claim was subsumed by the First Amendment claim and also barred by qualified immunity. The procedural due process claim was foreclosed by precedent, and the substantive due process claim was barred under en banc precedent.
What it means going forward
The decision reinforces that former employees challenging vaccine mandates must identify a clearly established right and seek prospective relief to survive a motion to dismiss, while confirming that qualified immunity remains a robust barrier for individual capacity claims in this context.