Background
Plaintiffs, who were firefighters for the Washington Department of Natural Resources, were terminated after declining to receive a COVID-19 vaccine due to religious beliefs. They sued the Department and the Commissioner of Public Lands, alleging violations of the Free Exercise Clause, Equal Protection Clause, and Due Process Clause under Section nineteen eighty-three. The district court dismissed the claims with prejudice, and the plaintiffs appealed.
The court’s reasoning
The court affirmed the dismissal on multiple grounds. First, the Department of Natural Resources is an arm of the state and not a person subject to suit under Section nineteen eighty-three, so the claims are barred by the Eleventh Amendment. Second, claims against the Commissioner in her official capacity are barred because the mandate was rescinded before the suit was filed, meaning there is no ongoing violation to redress. Third, the Commissioner is entitled to qualified immunity for claims in her personal capacity because the law was not clearly established that her vaccine mandate violated the Free Exercise, Equal Protection, or Due Process Clauses at the time of the terminations.
What it means going forward
The ruling reinforces that state agencies cannot be sued for damages under federal civil rights statutes and that officials are shielded from liability when the constitutional boundaries of vaccine mandates were not clearly defined at the time of enforcement.