Roberts v. Bassett

CourtDistrict Court, E.D. New York
DecidedMarch 15, 2022
Docket1:22-cv-00710
StatusUnknown

This text of Roberts v. Bassett (Roberts v. Bassett) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Roberts v. Bassett, (E.D.N.Y. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK JONATHAN ROBERTS and CHARLES VAVRUSKA, MEMORANDUM & ORDER Plaintiffs, 22-CV-710 (NGG) (RML) -against- MARY T. BASSETT, in her official capacity as Commissioner for NEW YORK STATE DEPARTMENT OF HEALTH, and the DEPARTMENT OF HEALTH AND MENTAL HYGIENE OF THE CITY OF NEW YORK, Defendants.

NICHOLAS G. GARAUFIS, United States District Judge. Plaintiffs Jonathan Roberts and Charles Vavruska request that this court issue a preliminary injunction to enjoin Mary T. Bas- sett, the Commissioner of the New York State Department of Health (the “State Defendant”) and the Department of Health and Mental Hygiene of the City of New York (““DOHMH” or the “City Defendant,” collectively, “Defendants”) from distributing COVID-19 treatments on the basis of race. For the reasons ex- plained below, this court lacks subject matter jurisdiction over this dispute because Plaintiffs have not demonstrated Article I] standing. Thus, as there is no case or controversy before this court, the court declines to consider Plaintiffs’ motion for a pre- liminary injunction, and the case is DISMISSED. I. BACKGROUND In December 2021, the Food and Drug Administration CFDA”) issued Emergency Use Authorization (“EUA”) for several promis- ing new oral antiviral therapies, including Paxlovid, Molnupiravir, and Sotrovimab (the “Treatments”), to treat

COVID-19.! (State Def.’s Mem. in Opp. to Pl’s Mot. for Prelim. Inj. at 2-3 (State’s Opp.) (Dkt. 22).) The FDA authorized the Treatments for individuals “who are at high risk for progression to severe COVID-19.”2 The EUA provides that “information on medical conditions and factors associated with increased risk for progression to severe COVID-19” can be found on the “People with Certain Medical Conditions” page of the United States Cen- ters for Disease Control and Prevention (“CDC”) website. 3 During the Omicron surge this winter, there were shortages of the Treatments in New York. (PI’s Mem. in Supp. of. Mot. for Prelim. Inj. at 1 (Mot.) (Dkt. 19); State’s Opp. at 3.) Given the limited supply of the Treatments, on December 27, 2021, the State Defendant and Gity Defendant published guidance for allo- cating them. The State’s guidance (“State Guidance”), which is addressed to “Health Care Providers and Health Care Facilities,” informs pro- viders that “[s]upplies of oral antivirals will be extremely limited initially.” (Dec. 27, 2020 Mem. to Providers at 2 (Dkt. 1-4).) As a result, “[w]hile supplies remain low,” providers are instructed to “adhere to the NYS DOH guidance on prioritization” and “pri- oritize therapies for people of any eligible age who are moderately to severely immunccompromised regardless of vac- cination status or who are age 65 and older and not fully vaccinated with at least one risk factor for severe illness.” Ud.)

1 Sotromivab was the only authorized monoclonal antibody therapeutic expected to be effective against the Omicron variant. 2 Food & Drug Admin., Emergency Use Authorization for Paxlovid (Dec. 22, 2021), https://www.fda.gov/media/155049/download; see also Food & Drug Admin., Emergency Use Authorization for Molnupiravir (Feb. 4, 2022), https://www.fda.gov/media/155053/download; Food & Drug Ad- min., Emergency Use Authorization for Sotrovimab (Feb. 23, 2022), https://www fda.gov/media/149532/download; Food & Drug Admin., Frequently Asked Questions on the Emergency Use Authorization of Sotro- vimab (Feb, 23, 2022), https://www.fda.gov/media/149535/download. 3 Ctrs, for Disease Control & Prevention, People With Certain Medical Con- ditions (Feb. 25, 2022), https://Awww.cdc.gov/coronavirus/2019- ncov/need-extra-precautions/people-with-medical-conditions.html.

The State Guidance provides that the Treatments are authorized for patients who (i) are twelve or older, (ii) test positive for COVID-19, (iii) have mild to moderate symptoms, (iv) are able to start treatment within five days of symptom onset, and (vy) have a medical condition or other factors that increase risk for severe illness. (id. at 3.) With respect to risk factors, the State Guidance explains that “[n]on-white or Hispanic/Latino ethnic- ity should be considered a risk factor, as longstanding systemic health and social inequities have contributed to an increased risk of severe illness and death from COVID-19.” Cd.) The State Guidance also includes a table that delineates how to prioritize distribution of the Treatments during “times of re- source limitations.” (Prioritization Guidance at 2 (Dkt. 1-5).) The table creates risk groups based on vaccination, age, immunocom- promised status, and a number of “risk factors for severe illness.” (id, at 3.) The Guidance provides a recommended approach and notes of prioritization for each risk group. At issue here is a note that provides that “[n]on-white race or Hispanic/Latino ethnicity should be considered a risk factor, as longstanding systemic health and social inequities have contributed to an increased risk of severe illness and death from COVID-19.” (Id. at 4.) Though the guidance does not explicitly define “risk factors for severe ill- ness,” it cites to the same CDC webpage with risk factors referenced in the FDA’s FUAs. Ud.) Those federal risk factors in- clude “racial and ethnic minority groups.” On March 4, 2022, the State Defendant issued new guidance, which advises that the Treatments are now “widely available” and that the federal government’s Test to Treat program, which began the week of March 7, 2022, “will provide increased avail- ability of immediate testing and early treatment.” (Mar. 4, 2022 State Guidance (Dkt. 31-1).) The City’s Health Advisory #39 (the “City Guidance”) directs health care providers to “adhere to the New York State Depart- ment of Health... guidance on prioritization of high-risk patients . . . during this time of severe resource limitations.”

(Health Advisory #39 at 2 (Dkt. 1-6).) The City Guidance reiter- ates the eligibility criteria from the State Guidance and adds: “Consider race and ethnicity when assessing an individual's risk. Impacts of longstanding systemic health and social inequities put Black, Indigenous, and People of Color at increased risk of severe COVID-19 outcomes and death.” Ud. at 4.) On February 1, 2022, the City Defendant issued Health Advisory #2, which superseded the challenged guidance. (March 2, 2022 Tr. 32:16-23.) The new advisory notes that the treatments are in stock, but that “supplies remain limited.”* Plaintiff Jonathan Roberts is a vaccinated 61-year-old non-His- panic and white resident of Manhattan with no known risk factors; his co-Plaintiff Charles Vavruska is a vaccinated 55-year- old non-Hispanic and white resident of Queens, and is over- weight or obese, which is considered a risk factor. (Mot. at 6.) Plaintiffs assert that they are entitled to access to the ‘Treatments on an equal basis, without regard to their race. Roberts, who does not meet the eligibility requirements, contends that he is entirely denied access to the drugs. Cd. at 8.) Plaintiffs allege that this scheme makes race determinative in two ways. First, among members in the same risk group, individuals who ate non-white or Hispanic receive higher priority for treat- ment over those who are of the same age and have the same race- neutral risk factors. (id. at 4.) Second, being a member of any minority group could move an individual to a higher risk group. (id.) On this basis, Plaintiffs contend that Defendants have vio- lated the equal protection clause of the Fourteen Amendment in issuing the challenged guidance. Defendants assert that the directives are merely guidance to be used in emergency periods of limited supplies and do not sup- plant the judgment of a medical provider. (State’s Opp. at 3.)

4N.Y.C, Dep’t of Health & Mental Hygiene, Health Advisory #2: Paxlovid is Available for COVID-19 Treatment in New York City (Feb. 1, 2022), https://www1 nyc.

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Roberts v. Bassett, Counsel Stack Legal Research, https://law.counselstack.com/opinion/roberts-v-bassett-nyed-2022.