Katie Sczesny v. Philip Murphy

CourtCourt of Appeals for the Third Circuit
DecidedMarch 14, 2025
Docket24-1676
StatusUnpublished

This text of Katie Sczesny v. Philip Murphy (Katie Sczesny v. Philip Murphy) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Katie Sczesny v. Philip Murphy, (3d Cir. 2025).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ____________

No. 24-1676 ____________

KATIE SCZESNY; JAMIE RUMFIELD; DEBRA HAGEN; MARIETTE VITTI,

Appellants

v.

PHILIP MURPHY, in his official and personal capacity; STATE OF NEW JERSEY ____________

On Appeal from the United States District Court for the District Court of New Jersey (D.C. Civil No. 3:22-cv-02314) District Judge: Honorable Zahid N. Quraishi ____________

Argued on January 17, 2025 ____________

Before: PHIPPS, FREEMAN, and CHUNG, Circuit Judges

(Filed: March 14, 2025)

Dana Wefer [ARGUED] LAW OFFICES OF DANA WEFER 290 Hackensack Street P.O. Box 374 Woodridge, NJ 07075

Counsel for Appellants Francis X. Baker [ARGUED] Daniel M. Vannella OFFICE OF ATTORNEY GENERAL OF NEW JERSEY 25 Market Street Richard J. Hughes Justice Complex P.O. Box 112 Trenton, NJ 08625

Counsel for Appellees

_______________

OPINION * _______________

FREEMAN, Circuit Judge.

In April 2022, four nurses sued the State of New Jersey and its Governor, Philip

Murphy, to challenge three of Murphy’s executive orders. The executive orders required

certain private healthcare companies to maintain COVID-19 vaccination requirements for

their employees. After Governor Murphy rescinded the executive orders, the District

Court dismissed the case as moot. We will affirm the District Court’s order.

I1

This case concerns three executive orders issued between January and April 2022.

First, Executive Order 283 required certain healthcare companies to maintain COVID-19

vaccination policies requiring workers to be “up to date with their COVID-19

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. 1 Because we write primarily for the parties, we recite only the facts necessary to our decision.

2 vaccinations.” App. 100. It also required those vaccination policies to “include a

disciplinary process for covered workers’ noncompliance, which may include termination

of employment.” App. 101. Several weeks later, Executive Order 290 updated the

deadlines by which workers needed to provide proof of vaccination. Lastly, Executive

Order 294 clarified that “up to date” vaccination included only the first booster for which

a worker was eligible.

Four nurses—Debra Hagen, Jamie Rumfield, Katie Sczesny, and Mariette Vitti—

are former employees of the Hunterdon Medical Center (“HMC”) in New Jersey. Each

nurse received an initial round of vaccination for COVID-19 but declined to receive a

booster dose due to her medical history and the risk of side effects. In April 2022, HMC

fired Rumfield, Sczesny, and Vitti for non-compliance with its vaccination policy, and

Hagen resigned to avoid having a termination for cause on her employment record.

That same month, the four nurses sued Governor Murphy and the State of New

Jersey. They claimed that Executive Orders 283, 290, and 294 violate the United States

Constitution. They sought a declaration that the executive orders are unconstitutional as

applied to them, plus attorneys’ fees and any other relief that may be just and equitable.

The District Court denied the nurses’ motion for a preliminary injunction, and the

nurses filed an interlocutory appeal. In June 2023, while the interlocutory appeal was

pending, Governor Murphy issued Executive Order 332, which rescinded the challenged

executive orders. Our Court dismissed the interlocutory appeal as moot and instructed

the District Court to consider on remand whether the underlying case was moot. See

Sczesny v. Murphy, No. 22-2230, 2023 WL 4402426, at *1 (3d Cir. June 14, 2023). The

3 District Court determined that the rescission of the challenged orders meant it could not

grant the nurses any relief. It also determined that no exception to mootness applied, so it

dismissed the case as moot. The nurses timely appealed.

II 2

“A case generally is moot when in the course of litigation, a court finds that it can

no longer provide a plaintiff with any effectual relief.” Road-Con, Inc. v. City of Phila.,

120 F.4th 346, 356 (3d Cir. 2024) (cleaned up). For instance, when a party seeks only

prospective relief from a challenged law, the recission of that law moots the claim. See

N.Y. State Rifle & Pistol Ass’n, Inc. v. City of N.Y., 590 U.S. 336, 338–39 (2020)

(deeming claims moot where, during the Supreme Court’s review, the State of New York

amended the challenged statute in a way that provided the challengers with the equitable

relief they requested in their complaint); Trump v. Hawaii, 583 U.S. 941, 941 (2017)

(Mem.) (deeming a case moot where the challenged executive order expired by its own

terms).

We have applied this principle to COVID-19 related executive orders in two

precedential opinions. Both times, when the challenged orders expired or were

rescinded, we held that claims for declaratory or injunctive relief were moot. Clark v.

Governor of N.J., 53 F.4th 769, 776 (3d Cir. 2022) (concluding that a challenge to

2 At the outset of this case, the district court had federal question jurisdiction under 28 U.S.C. §§ 1331 & 1343. Regardless of whether the case is moot, we have jurisdiction to review the District Court’s final order under 28 U.S.C. § 1291. Hartnett v. Pa. State Educ. Ass’n, 963 F.3d 301, 305 (3d Cir. 2020). We review questions of mootness de novo. Weitzner v. Sanofi Pasteur, Inc., 819 F.3d 61, 64 (3d Cir. 2016).

4 executive orders restricting in-person gatherings was “facially moot” because the orders

had been rescinded in relevant part, leaving “no effectual relief whatsoever that this Court

may grant in relation to those orders” (cleaned up)); Cnty. of Butler v. Governor of Pa., 8

F.4th 226, 230 (3d Cir. 2021) (deeming a challenge to stay-at-home orders, business

closure orders, and orders limiting congregation sizes moot because the orders expired,

leaving “no relief that this Court can grant concerning them”), cert. denied, 142 S. Ct.

772 (2022) (Mem.).

Such is the case here. The nurses are seeking declaratory relief from now-

rescinded executive orders. This Court can grant no effectual relief from those orders, so

this case is facially moot. 3

Despite facial mootness, we are “particularly skeptical” of deeming a claim moot

based on an action a defendant “took unilaterally after the litigation began.” Hartnett v.

Pa. State Educ. Ass’n, 963 F.3d 301, 306–07 (3d Cir. 2020). Thus, voluntary cessation of

a challenged practice will only moot a case if it is “absolutely clear that the alleged

wrongful behavior could not reasonably be expected to recur.” Clark, 53 F.4th at 775

(quoting Fields v. Speaker of the Pa. House of Representatives, 936 F.3d 142, 161 (3d

3 The nurses argue that this case is not facially moot because they all remain separated from their employment at HMC and three of them have terminations on their employment records. Even assuming those injuries are fairly traceable to the challenged executive orders, the injuries are not redressable by this Court.

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