Dr. T. v. McKee

CourtDistrict Court, D. Rhode Island
DecidedSeptember 30, 2021
Docket1:21-cv-00387
StatusUnknown

This text of Dr. T. v. McKee (Dr. T. v. McKee) is published on Counsel Stack Legal Research, covering District Court, D. Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dr. T. v. McKee, (D.R.I. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODE ISLAND

) DR. T., NURSE L., HOSP. CLERK ) M., and HEALTH UNIT ) COORDINATOR L. ) ) Plaintiffs, ) ) v. ) C.A. No. 1:21-cv-00387-MSM-LDA )

NICOLE ALEXANDER-SCOTT, in ) her official capacity as Director of the ) Rhode Island Department of Health, ) and DANIEL J. MCKEE in his official ) capacity as Governor of the State of ) Rhode Island, ) ) Defendants. )

ORDER

Mary S. McElroy, United States District Judge.

I. INTRODUCTION

The plaintiffs in this matter, all healthcare workers, seek injunctive relief against the enforcement of Rhode Island Department of Health (“RIDOH”) Emergency Regulation 216-RICR-20-15-8, promulgated August 17, 2021, which requires all healthcare workers, except those meeting a very narrow medical exception, to be vaccinated against COVID-19 by October 1, 2021. The plaintiffs claim that because this Regulation does not include an opportunity for a healthcare worker to obtain a religious exemption to vaccination, it violates the United States Constitution and Title VII of the Civil Rights Act of 1964. Before the Court is the plaintiffs’ motion for a temporary restraining order (“TRO”). They ask the Court to enjoin the RIDOH from enforcing any requirement that employers deny religious exemptions from COVID-19 vaccination or that they revoke any exemptions employers already granted before the Regulation; that the

RIDOH be barred from interfering with the granting of religious exemptions going forward; and from taking any disciplinary action against the plaintiffs for seeking or having obtained a religious exemption. This matter was filed on September 23, 2021. The Court conferenced the matter with the parties the following day, at which time both parties agreed that the Court should schedule a hearing on the motion for a TRO and not on a preliminary

injunction. Argument on the motion for a TRO was held on September 29, 2021, at which time the plaintiffs asked that the Court, if it was to deny the request for a TRO, also issue an order denying a preliminary injunction. The defendants objected to the consideration of a preliminary injunction at this juncture, citing the desire to further develop the factual record. The Court finds that the defendants would be unduly prejudiced if not afforded this opportunity. The plaintiffs filed this action eight days before the Regulation’s vaccination deadline

though the Regulation was announced on August 17, 2021. The defendants prepared themselves for an expedited hearing on the TRO but, given the issues that came up in that hearing, now believe that they need more time to determine if they wish to present additional evidence or further briefing at a hearing on the plaintiffs’ motion for a preliminary injunction. The Court therefore denies the plaintiffs’ request to issue a ruling on their request for a preliminary injunction and instead proceeds to decide their motion for a TRO. II. LEGAL STANDARD

Temporary restraining orders are an extraordinary remedy; they “must be used sparingly and only in cases where the need for extraordinary equitable relief is clear and plain.” , 453 F. Supp. 2d 333, 338 (D.N.H. 2006) (quoting , 750 F. Supp. 28, 31 (D. Me. 1990)). To determine whether to grant a TRO, the Court considers four well-established prongs:

(1) the likelihood of success on the merits; (2) the potential for irreparable harm if the injunction is denied; (3) the balance of relevant impositions, i.e., the hardship to the nonmovant if enjoined as contrasted with the hardship to the movant if no injunction issues; and (4) the effect (if any) of the court’s ruling on the public interest.

, 102 F.3d 12, 15 (1st Cir. 1996). The first prong is absolutely necessary; without establishing a strong likelihood of prevailing on the merits as opposed to a mere possibility of success, the other prongs are irrelevant. , 699 F.3d 1, 10 (1st Cir. 2012) (quoting , 622 F.3d 13, 15 (1st Cir. 2010)). The plaintiffs bear the burden of demonstrating that these factors weigh in their favor. , 353 F.3d 108, 120 (1st Cir. 2003). III. DISCUSSION The plaintiffs raise the following claims:

• That the Regulation impermissibly burdens the plaintiffs’ right to free exercise of religion under the First Amendment to the United States Constitution. • That the Regulation compels healthcare facilities to disregard Title VII of the Civil Rights Act of 1964’s protection against employment

discrimination on the basis of religion. • That the Regulation is an unconstitutional abridgment of the plaintiffs’ right to equal protection under the Fourteenth Amendment to the United States Constitution.

The Court finds that the plaintiffs have not demonstrated a likelihood of success on the merits of these claims. As to the constitutional claims, courts have held for over a century that mandatory vaccination laws are a valid exercise of a state’s police powers, and such laws have withstood constitutional challenges. , , 494 U.S. 872, 889 (1990) (identifying “compulsory vaccination laws” as among the neutral, generally applicable laws that did not

require religious exemptions under the First Amendment); , 321 U.S. 158, 166-67, n.12 (1944) (noting that the right to practice one’s religion freely “does not include liberty to expose the community … to communicable disease”); , 260 U.S. 174, 176-77 (1922) (holding that there was no equal protection violation where child prohibited from attending school without vaccinations, and explaining that “in the exercise of the police power reasonable classification may be freely applied, and that regulation is not violative of the equal protection clause

merely because it is not all- embracing”); , 197 U.S. 11, 25- 27 (1905) (holding that mandatory vaccination laws do not offend “any right given or secured by the Constitution,” and that a state’s police power allows imposition of “restraints to which every person is necessarily subject for the common good”). The plaintiffs’ second claim for relief alleges that the Regulation compels heathcare facilities in the State of Rhode Island to disregard Title VII of the Civil

Rights act and thereby violates the Supremacy Clause to the U.S. Constitution, Art. VI, cl. 2. The defendants argue in response that the Supremacy Clause does not create a private right of action and that the Regulation does not compel healthcare facilities to refuse to consider religious accommodation and, therefore, does not violate Title VII. The Supreme Court has held that reading a private right of action into the Supremacy Clause would be “strange” given the Constitution’s “silen[ce] regarding

who may enforce federal laws in court, and in what circumstances they may do so,” and that the result of permitting a private right of action would be to “significantly curtail [Congress’s] ability to guide the implementation of federal law.” ., 575 U.S. 320, 325-26 (2015). However, the Title VII analysis cannot end there.

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Dr. T. v. McKee, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dr-t-v-mckee-rid-2021.