Martin v. International Organization of Masters, Mates & Pilots, et al.
Martin v. International Organization of Masters, Mates & Pilots, et al.
June 10, 2026·25-829·Unpublished·By Aisha Johnson
The Ninth Circuit affirmed a district court dismissal of a civil rights claim alleging a conspiracy to interfere with vaccination rights. The panel held that the plaintiff failed to establish a right protected against private encroachment under the relevant statute.
Daniel Martin appealed a district court judgment dismissing his claim under 42 U.S.C. Section 1985(3) against the International Organization of Masters, Mates & Pilots and Matson Navigation Company, Inc. for failure to state a claim.
The court’s reasoning
The court reviewed the dismissal de novo, accepting all nonconclusory factual allegations as true. To state a claim under Section 1985(3), a plaintiff must show class-based invidiously discriminatory animus and that the conspiracy aimed at interfering with rights protected against both private and official encroachment. The court found that Martin failed to establish the existence of any right protected against private encroachment, noting that even assuming a fundamental constitutional right to refuse vaccination exists, no authority suggests such a right is protected against private encroachment.
What it means going forward
The decision reinforces the high bar for establishing private rights under Section 1985(3) and limits the statute’s application to rights with explicit federal protection against private interference.
