Memorandum of Law in Support of TRO — Children's Health Defense v. Rutgers (D.N.J.)

Record facts

No. 3:21-cv-15333-ZNQ-TJB · Doc. 10-1 · 2021-08-30 · Docket on CourtListener

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Julio C. Gomez, Esq. 
GOMEZ LLC ATTORNEY AT LAW 
1451 Cooper Road 
Scotch Plains, NJ 07076 
Tel 908.789.1080 
Fax 908.789.1081 
Attorney for Plaintiffs 
 
 
UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF NEW JERSEY 
CHILDREN’S HEALTH DEFENSE, INC., 
PETER CORDI, RAELYNNE MILLER, 
KAYLA MATEO, ADRIANA PINTO, 
JAKE BOTHE, AND DOES 1-13, 
 
 
Plaintiffs, 
Case No. 3:21-cv-15333 
(ZNQ-TJB) 
 
-against- 
 
 
 
RUTGERS, THE STATE UNIVERSITY 
OF NEW JERSEY, BOARD OF 
GOVERNORS, RUTGERS SCHOOL OF 
BIOMEDICAL AND HEALTH 
SCIENCES, CHANCELLOR BRIAN L. 
STROM, PRESIDENT JONATHAN 
HOLLOWAY, in their official capacities. 
 
 
Defendants 
 
 
 
 
MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFFS’ MOTION 
FOR A TEMPORARY RESTRAINING ORDER PURSUANT TO FED. R. 
CIV. P. 65 REQUIRING DEFENDANTS TO COMPLY WITH THEIR OWN 
UNIVERSITY POLICY SECTION 10.3.14. 
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TABLE OF CONTENTS 
 
 
TABLE OF AUTHORITIES…..…………………………………………………..ii 
 
STATEMENT OF FACTS ……………………………………..…….……………1 
 
STANDARD FOR A TEMPORATY RESTRAINING ORDER…….……………5 
 
ARGUMENT ………………………………………………………………………6 
 
I. 
PLAINTIFF IS LIKELY TO SUCCEED ON THE MERITS BECAUSE 
RUTGERS IS ACTING ARBITRARILY AND CAPRICIOUSLY BY 
DEVIATING FROM ITS OWN POLICY AND REQUIRING MS. PINTO 
TO TAKE A COVID VACCINE EVEN THOUGH HER COURSE OF 
STUDY IS FULLY REMOTE AND SHE WILL NOT SET FOOT ON 
CAMPUS ……….………………………………………………………….6 
 
II. 
MS. 
PINTO 
IS 
IRREPARABLY 
HARMED 
BECAUSE 
HER 
CONSTITUTIONAL RIGHTS ARE BEING VIOLATED………………..9 
 
III. GRANTING A TEMPORARY RESTRAINING ORDER WILL HAVE 
LITTLE TO NO EFFECT ON THE DEFENDANTS……………………10 
 
IV. 
GRANTING A TEMPORARY RESTRAINING ORDER IS IN THE 
PUBLIC INTEREST………………………………………………………10 
 
CONCLUSION …………………………………………………………………..12 
 
 
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TABLE OF AUTHORITIES 
 
Cases 
 
Albro v. County of Onondonga, New York, 
627 F. Supp. 1280 (N.D.N.Y. 1986) ……………………………………………….9 
 
Assisted Living Associates of Moorestown, L.L.C. v. Moorestown Township, 
996 F. Supp. 409 (D.N.J. 1998) ……………………………………………………5 
 
Cruzan v. Director, Missouri Dept. of Health, 
497 U.S. 261 (1990) ………………………………………………………………6 
 
First Puerto Rican Festival of New Jersey, Inc. v. City of Vineland, 
108 F. Supp.2d 392 (D.N.J. 1998) …………………………………………………5 
 
Fortune Society v. McGinnis, 
319 F. Supp 901 (S.D.N.Y. 1970) …………………………………………………9 
 
Gorman v. Coogan, 
273 F. Supp. 2d 131 (D. Me. 2003) ……………………………………………….5 
 
Hohe v. Casey, 
868 F.2d 69, 72-74 (3d Cir. 1989) …………………………………………………9 
 
Jacobson v. Massachusetts, 
197 U.S. 11 (1905) ………………………………………………………………...6 
 
Long Term Care Pharmacy Alliance v. Ferguson, 
260 F. Supp. 2d 282 (D. Mass. 2002) ……………………………………………...5 
 
Mitchell v. Cuomo, 
748 F.2d 804 (2d Cir. 1984) ……………………………………………………….9 
 
Northern Penna Legal Services, Inc. v. County of Lackawana, 
513 F. Supp. 678 (M.D.Pa. 1981) ………………………………………………….9 
 
Philadelphia Vietnam Veterans Memorial Society v. Kenney, 
509 F. Supp. 3d 318, 327 (E.D.Pa. 2020) ………………………………………….9 
 
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Schulz v. Unites States Boxing Assoc., 
105 F.3d 127 (3d Cir. 1997) ……………………………………………………….5 
 
Union Pacific R. Co. v. Botsford, 
141 U.S. 250 (1891) ………………………………………………………………7 
 
Washington v. Harper,  
494 U.S. 210 (1990) ………………………………………………………………7 
 
Westchester Legal Services, Inc. v. Westchester County 
607 F. Supp. 1379 (S.D.N.Y. 1985) ………………………………………………9 
 
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Plaintiff Children’s Health Defense, Inc. (“CHD”) and Plaintiff Adriana 
Pinto (“Ms. Pinto”) (collectively, “Plaintiffs”), through their undersigned attorney, 
respectfully request that this Court issue a temporary restraining order enjoining 
Defendants from enforcing Rutgers University Policy Section 10.3.14 (the 
“Policy”), which mandates COVID-19 vaccination, against Ms. Pinto in an 
arbitrary and capricious manner, by requiring her to get vaccinated for COVID-19 
even though she is enrolled in a “fully remote” class schedule and will not set foot 
on campus, in violation of the Due Process Clause of the Fourteenth Amendment. 
STATEMENT OF FACTS 
On or about January 22, 2021, Rutgers told the public and the student body 
that it would not mandate COVID-19 vaccination for students to return to campus 
for in-person instruction because it valued medical freedom.  Verified Complaint ¶ 
170.1 
 
1 In a video sent to students and staff, Rutgers Biomedical and Health Sciences 
Senior Vice Chancellor Vicente Gracias assured viewers that Rutgers would not 
mandate COVID-19 vaccines based upon a history and tradition at the University 
of promoting human liberty.  Complaint ¶ 170.  Vice Chancellor Gracias 
emphasized that education would serve as the driver for vaccination at Rutgers, not 
coercion, and that the University could rotate in-person schedules or attendance as 
an added safety measure to welcome students back to campus for in-person 
instruction.  Complaint ¶ 170.  Certain Plaintiffs relied on Rutgers’ representation 
that it would not mandate COVID-19 vaccines in order to accept offers of 
admission to its colleges, avoid seeking transfers to other colleges and universities, 
or entertain other alternatives to in-person attendance.  Complaint ¶ 171.   
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Two months later, on March 25, 2021, Rutgers reversed itself and 
announced that it would now mandate COVID-19 vaccines for all students in the 
Fall 2021 Semester.  Verified Complaint ¶ 173. 
On April 13, 2021, Rutgers formally adopted policy section 10.3.14 entitled, 
“Interim COVID-19 Immunization Record Requirement for Students” (the 
“Policy”), which details the COVID-19 immunization record requirements for all 
Rutgers University students.  Verified Complaint ¶ 175; see also Ex. A to the 
Declaration of Counsel filed contemporaneously with this motion (“Counsel 
Decl.”). 
The Policy requires all students to present evidence of COVID-19 
vaccination with one of the currently emergency-use authorized COVID-19 
vaccines.  Verified Complaint ¶ 175.  Students are required to upload evidence of 
immunization to the online Rutgers Immunization Portal prior to arrival on 
campus.  Verified Complaint ¶ 175. 
Rutgers’ Policy exempts certain students from COVID-19 vaccination: (1) 
students who request and qualify for a medical exemption; (2) students who 
request and qualify for a religious exemption; and (3) students whose course of 
study is “fully remote” (the subject of this motion). 
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Rutgers’ Policy reads, in pertinent part: 
II. Exemptions for Requirements  
 
Other than the exceptions/exemptions listed below, 
this interim policy shall apply to every student 
matriculated or enrolled full-time or part-time in a 
Rutgers school or program, including joint and 
collaborative programs with other institutions, and to 
all visiting, exchange, and special-program students 
from other institutions. 
 
A. Students whose entire course of study is entirely 
web-based, a fully online degree program, and/or 
fully remote. To qualify, the student must have no 
physical presence on campus. 
Rutgers Policy Section 10.3.14 (emphasis added) (Counsel Decl. Ex. A). 
Additionally, there is no penalty or sanction provision expressed in the 
Policy for a student’s failure to submit evidence of COVID-19 immunization.  
Verified Complaint ¶ 176; Counsel Decl. Ex. A.  Presumably, the privilege of 
attending Rutgers in-person is subject to compliance with the Policy.  Verified 
Complaint ¶ 176.  The Policy does not state that students will be expelled or 
disenrolled from Rutgers if they do not comply with the Policy; the Policy also 
does not state that students will be blocked from accessing their online accounts 
(known as NetID my.rutgers.edu accounts), or anything else, for noncompliance.  
Verified Complaint ¶ 176; Counsel Decl. Ex. A. 
Nevertheless, on August 26, 2021, Rutgers began to penalize students who 
are exempt under the Policy (because they have enrolled in a “fully remote” class 
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schedule) by sending those students a misleading message that they are 
“Noncompliant” and by blocking them from their online accounts – which will 
prevent them from signing into classes on September 1, the first day of class at 
Rutgers. 
Plaintiff Adriana Pinto is a senior at Rutgers, majoring in psychology with a 
minor in education. See Declaration of Adriana Pinto, ¶ 2, filed contemporaneously 
(“Pinto Decl.”).  Ms. Pinto is also a lifetime member of Plaintiff Children’s Health 
Defense, Inc.  Pinto Decl. ¶ 1.  Ms. Pinto needs to take one final class to complete 
the coursework for her degree and qualify to graduate.  Pinto Decl. ¶ 2.  Ms. Pinto 
has not asserted a medical exemption to vaccination yet; she has not asserted a 
religious exemption to vaccination; relying on the express terms of Rutgers’ 
Policy, Ms. Pinto enrolled in a fully remote schedule by registering to take the one 
last class she needs to graduate online, the class is Quantitative Methods.  Pinto 
Decl., ¶¶ 2, 7-10.  
On or about August 26, 2021, Rutgers blocked Ms. Pinto from her online 
account with a Notice stating that she is not compliant with the Policy and must 
upload evidence of COVID-19 vaccination.  Pinto Decl. ¶ 9 and Ex. A and B.  As a 
result, she cannot access her course schedule and she will not be able to log-in to 
her class on Monday, September 1, 2021, to start the final course she will need to 
graduate from college.  Pinto Decl. 9-10, Ex. A and B. 
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STANDARD FOR A TEMPORARY RESTRAINING ORDER 
The requirements for a temporary restraining order are identical to the 
requirements for a preliminary injunction.  See Gorman v. Coogan, 273 F. Supp. 
2d 131, 133-34 (D. Me. 2003); Long Term Care Pharmacy Alliance v. Ferguson, 
260 F. Supp. 2d 282, 288-89 (D. Mass. 2002).  In both instances, injunctive relief 
is appropriate if the moving party demonstrates: “(1) a likelihood of success on the 
merits; and (2) the probability of irreparable harm if relief is not granted.”  First 
Puerto Rican Festival of New Jersey, Inc. v. City of Vineland, 108 F. Supp.2d 392, 
394 (D.N.J. 1998) (quoting Assisted Living Associates of Moorestown, L.L.C. v. 
Moorestown Township, 996 F. Supp. 409, 433 (D.N.J. 1998) (citing e.g., Schulz v. 
Unites States Boxing Assoc., 105 F.3d 127, 131 n. 6 (3d Cir. 1997).  “In addition to 
these showings by the moving party, the Court must also consider: (3) the effect of 
the grant of preliminary relief on the non-moving party; and (4) whether the public 
interest will be served by the preliminary injunctive relief.”  Id.  Each of these 
factors supports the entry of a temporary restraining order against Rutgers 
maintaining the status quo and requiring Rutgers to follow the language of its own 
Policy and exempt Ms. Pinto (and any other student) who has enrolled in fully-
remote classes, from the requirement to get a COVID-19 vaccine, to remove the 
notices in their online accounts stating that these students are “noncompliant” and 
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to allow them full-access to their online accounts so that they can start classes on 
Wednesday, September 1, 2021. 
ARGUMENT 
I. 
PLAINTIFF IS LIKELY TO SUCCEED ON THE MERITS BECAUSE 
RUTGERS IS ACTING ARBITRARILY AND CAPRICIOUSLY BY 
DEVIATING FROM ITS OWN POLICY AND REQUIRING MS. 
PINTO TO TAKE A COVID VACCINE EVEN THOUGH HER 
COURSE OF STUDY IS FULLY REMOTE AND SHE WILL NOT 
SET FOOT ON CAMPUS. 
Ms. Pinto has a constitutionally guaranteed right to informed consent and to 
refuse unwanted medical treatment under the Due Process Clause of the Fourteenth 
Amendment.  See Cruzan v. Director, Missouri Dept. of Health, 497 U.S. 261, 269 
(1990) (“The principle that a competent person has a constitutionally protected 
liberty interest in refusing unwanted medical treatment may be inferred from our 
prior decisions.”) (citing Jacobson v. Massachusetts, 197 U.S. 11, 24-30 (1905) 
(“There is, of course, a sphere within which the individual may assert the 
supremacy of his own will and rightfully dispute the authority of any human 
government, especially of any free government existing under a written 
constitution, to interfere with the exercise of that will”). 
In Jacobson, the Supreme Court held that mandatory vaccination must be 
reasonable, necessary for public health, and proportional to the need. 197 U.S. at 
27-33 (“if a statute purporting to have been enacted to protect the public health, the 
public morals or the public safety, has no real or substantial relation to those 
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objects, or is, beyond all question, a plain, palpable invasion of rights secured by 
the fundamental law, it is the duty of the courts to so adjudge, and thereby give 
effect to the Constitution.”).  Later, in Cruzan, the Supreme Court held that a 
person has a liberty interest under the Due Process Clause in avoiding unwanted 
medical treatment that “must be determined by balancing his liberty interests 
against the relevant state interests.”  497 U.S. at 279 (holding that bodily integrity 
embodies the requirement that informed consent is generally required for medical 
treatment); see also, Washington v. Harper, 494 U.S. 210, 221-222 (1990) 
(recognizing a “significant liberty interest in avoiding unwanted administration of 
antipsychotic drugs under the Due Process Clause of the Fourteenth Amendment”); 
Union Pacific R. Co. v. Botsford, 141 U.S. 250, 251 (1891) (“[n]o right is held 
more sacred, or is more carefully guarded, by the common law, than the right of 
every individual to the possession and control of his own person, free from all 
restraint or interference of others, unless by clear and unquestionable authority of 
law.”). 
 
In this case, exercising those rights, Ms. Pinto researched COVID-19 
vaccines and elected not to take them because she has struggled with her health as 
a young adult, must adhere to strict requirements to stay healthy and does not want 
to undertake any unknown risk to her health from COVID-19 vaccines.  Pinto 
Decl. ¶¶ 3-4.  As a result, to protect herself and others from infection or 
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transmission of SARS-CoV-2, Ms. Pinto registered to take the sole class she needs 
to graduate remotely.  Pinto Decl. ¶¶ 7-8.   
On or about August 26, 2021, contrary to the express language of its own 
Policy, Rutgers blocked Ms. Pinto’s access to her online account because Rutgers 
considers her to be not in compliance with its Policy.  Pinto Decl. ¶ 9 and Ex. A 
and B.  As a result, she will be unable to log into her class via Zoom on September 
1, 2021, and she will be effectively shut out from taking classes this semester. 
 
Since there is no relationship – much less the “real or substantial relation” 
that Jacobson requires – between a policy mandating vaccination of students who 
will never set foot on campus and Rutgers’ purported interest in protecting the 
public health of the Rutgers community, Rutgers’ application of its Policy to Ms. 
Pinto (and other such students) is a “palpable invasion” of Ms. Pinto’s rights. 
Furthermore, by having a Policy that expressly states Ms. Pinto shall be 
exempt if she takes fully remote classes, and then taking action to block her from 
her account because she has not vaccinated anyway, Rutgers is acting arbitrarily 
and capriciously to deny Ms. Pinto her rights.  For these reasons, Ms. Pinto is 
likely to succeed on the merits of her Due Process Claim.2 
 
2 In their Verified Complaint, Ms. Pinto and the rest of the Plaintiffs in this case 
assert additional allegations that Rutgers’ Policy violates due process for other 
additional reasons; those assertions are not the subject of the instant narrow motion 
but preserved for adjudication later in the course of this litigation. 
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II. 
MS. PINTO IS IRREPARABLY HARMED BECAUSE HER 
CONSTITUTIONAL RIGHTS ARE BEING VIOLATED. 
Violations of constitutional rights are irreparable harm per se. See, e.g., 
Albro v. County of Onondaga, New York, 627 F.Supp. 1280, 1287 (N.D.N.Y.1986) 
(Munson, C.J.) (citing Mitchell v. Cuomo, 748 F.2d 804, 806 (2d Cir.1984); 
Fortune Society v. McGinnis, 319 F.Supp. 901, 903 (S.D.N.Y.1970)). See also, 
Westchester Legal Services, Inc. v. Westchester County, 607 F.Supp. 1379, 1382 
(S.D.N.Y.1985) (violation of First Amendment rights constitutes irreparable harm 
per se); Northern Penna. Legal Services, Inc. v. County of Lackawana, 513 
F.Supp. 678, 685 (M.D.Pa.1981).  In the Third Circuit, violations of constitutional 
rights can constitute irreparable harm per se when government directly penalizes 
someone for exercising their constitutional rights or creates a “chilling effect” on 
the free exercise of such rights.  See Philadelphia Vietnam Veterans Memorial 
Society v. Kenney, 509 F. Supp. 3d 318, 327 (E.D.Pa. 2020) (citing Hohe v. Casey, 
868 F.2d 69, 72-74 (3d Cir. 1989)).  This concept should apply outside the First 
Amendment context. 
Ms. Pinto is being irreparably harmed because Rutgers is coercing her to 
reverse the decision she made in the exercise of her right to informed consent and 
to refuse unwanted medical treatment.  It is a violation of Ms. Pinto’s rights for 
Rutgers penalize her by blocking her from her account and from taking her class, 
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solely because she exercised these rights and chose not to vaccinate for COVID-
19.  Such violations of Ms. Pinto’s constitutional rights are irreparable harm per se. 
III. 
GRANTING A TEMPORARY RESTRAINING ORDER WILL HAVE 
LITTLE TO NO EFFECT ON THE DEFENDANTS. 
Defendants contend that their Policy was adopted for health and safety 
reasons, and to protect the Rutgers community. Plaintiffs dispute that assertion.3  
However, even if this Court were to take Rutgers at its word, a restraining order 
requiring Rutgers to follow the express terms of its own Policy, and exempt 
students who are “fully remote” will not impact Rutgers’ purported health and 
safety concerns one iota, because Ms. Pinto (and other students like her) do not 
need to step foot on campus to continue their coursework and could not possibly 
contract or spread SARS-CoV-2 to anyone on campus. 
IV. 
GRANTING A TEMPORARY RESTRAINING ORDER IS IN THE 
PUBLIC INTEREST. 
The public has an interest in the protection of constitutionally guaranteed 
civil rights.  There is also a public interest in requiring public institutions to follow 
the dictates of their own policies.  Public entities should act in a consistent and 
 
3 Upon information and belief, Plaintiff also alleged that Rutgers was motivated, at 
least in part, by financial gain since it is working with all three COVID-19 
manufacturers to develop the Pfizer, Moderna and Johnson & Johnson vaccines.  
See e.g. Verified Complaint ¶¶ 8, 32, 33, 97, 103-117.  Plaintiffs also allege in their 
verified complaint that Rutgers’ Policy is not adequately tailored to achieve health 
and safety; it is overbroad and underinclusive.  See e.g. Verified Complaint ¶¶ 252-
287.   
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rational manner, not adopt policy and later arbitrarily take action that contradicts or 
conflicts with the policy adopted.  The public also has an interest in ensuring that 
mandates concerning COVID-19 have a “real and substantial relation,” Jacobson 
supra, to the health and safety interests they purport to further.  As the Court 
knows, overbroad mandates (e.g. government ordered shutdowns and community 
lockdowns) can have devastating human and economic consequences. 
More directly, at stake is every student’s right to exercise informed consent 
and to refuse medical treatment guaranteed by the Due Process Clause of the 
Fourteenth Amendment.  The public has an interest in Ms. Pinto and every member 
of our society having the right to decide what medical treatment to undertake and 
to refuse unwanted treatment if they so choose.  Cruzan, supra. 
In this case, Ms. Pinto exercised her rights, relied on Rutgers’ representation 
that she would be exempt from COVID-19 vaccination if she enrolled in a “fully 
remote” schedule, and enrolled in an on-line “fully remote” class – the last class 
she needs to complete her requirements to graduate.  Ms. Pinto enrolled in a “fully 
remote” class in order to protect herself and the Rutgers community from any 
infection or transmission of SARS-CoV-2. 
Rutgers does not seem to care that Ms. Pinto exercised her constitutional 
rights and made a responsible decision to enroll in a “fully remote” schedule.  For 
some unknown reason, Rutgers has decided to deviate from its own Policy and 
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block Ms. Pinto from her online account, presumably because it is dead set on 
forcing her take vaccines that it is helping to develop and manufacture.  Verified 
Complaint ¶ __.  It is in the public interest for this Court to protect Ms. Pinto’s 
decision, which is guaranteed by the Fourteenth Amendment, and permitted under 
Rutgers’ Policy, against the arbitrary and irrational conduct of Rutgers, and, order 
that Rutgers maintain the status quo, follow its Policy, and let her (and others like 
her) continue her coursework remotely, without COVID-19 vaccination, and 
complete her requirements to graduate. 
CONCLUSION 
For all of the foregoing reasons, Plaintiffs respectfully request that this Court 
issue a temporary restraining maintaining the status quo and require Defendants to 
follow Rutgers University Policy Section 10.3.14 which exempts students enrolled 
in fully-remote classes, ordering Rutgers to lift the block on Ms. Pinto’s account, 
and allowing her to attend her class remotely without COVID-19 vaccination. 
Respectfully submitted. 
August 30, 2021 
 
 
 
 
GOMEZ LLC 
 
 
 
 
 
 
 
ATTORNEY AT LAW 
 
 
 
 
 
 
 
By:  s/ Julio C. Gomez  
 
 
 
 
 
 
 
 
 
   Julio C. Gomez, Esq. 
1451 Cooper Road 
Scotch Plains, NJ 07076 
Tel 908.789.1080 
Fax 908.789.1081 
jgomez@gomezllc.com 
Attorney for Plaintiffs 
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