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Home Court filings Children's Health Defense, Inc. v. Rutgers Rutgers Reply Brief in Support of Motion to Dismiss — Children's Health Defense v. Rutgers (D.N.J.)

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Rutgers Reply Brief in Support of Motion to Dismiss — Children's Health Defense v. Rutgers (D.N.J.)

Filed January 31, 2022 in Childrens Health Defense v. Rutgers; one of 33 filings from this case.

Record facts

Filed2022-01-31

No. 3:21-cv-15333-ZNQ-TJB · Doc. 43 · 2022-01-31 · Docket on CourtListener

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FAEGRE DRINKER BIDDLE & REATH LLP 
Jeffrey S. Jacobson  
Andrew B. Joseph 
W. Joshua Lattimore 
Jennifer P. Montan  
600 Campus Drive 
Florham Park, New Jersey 07932 
(973) 549-7000 
(973) 360-9831 (fax) 
Jeffrey.Jacobson@faegredrinker.com 
Andrew.Joseph@faegredrinker.com 
Joshua.Lattimore@faegredrinker.com 
Jennifer.Montan@faegredrinker.com 
Attorneys for Rutgers, The State University of New Jersey, et al. 
 
IN THE 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, ANTHONY 
LAMANCUSA, JESSICA MOORE, RYAN
SANDOR, GIANNA CORALLO, AND 
RYAN FARRELL, AND DOES 2, 3, 6, 7, 9
AND 13,  
 
Plaintiffs, 
 
v. 
 
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. 
Civil Action No. 3:21-cv-15333-
ZNQ-TJB 
 
Civil Action 
 
(Document Filed Electronically) 
 
Return Date: February 7, 2022 
 
 
 
DEFENDANTS’ REPLY 
MEMORANDUM OF LAW 
IN SUPPORT OF THEIR 
MOTION TO DISMISS 
PLAINTIFFS’ FIRST 
AMENDED COMPLAINT 
PURSUANT TO FED. R. CIV. 
P. 12(B)(1) AND  
FED. R. CIV. P. 12(B)(6) 
 
 
 
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TABLE OF CONTENTS 
INTRODUCTION................................................................................................................ 1 
ARGUMENT ......................................................................................................................... 2 
I. 
Plaintiffs Misstate The Rights At Issue In Their Case ........................................ 2 
A. 
Jacobson forecloses Plaintiffs’ argument that they have a right to 
attend Rutgers without complying with Rutgers’ vaccination 
policy .............................................................................................................. 3 
B. 
Jacobson held that courts should defer to public health officials 
on questions of vaccines’ safety and efficacy. ........................................... 4 
C. 
This is not an “unconstitutional conditions” case .................................... 7 
D. 
“Unvaccinated” is not a protected class .................................................... 8 
II. New Jersey Law Empowers Rutgers To Mandate ACIP-Recommended 
Vaccinations, and ACIP Recommended the COVID-19 Vaccines .................. 9 
III. Plaintiffs Have No Claim for Breach of Contract or Equitable Estoppel
 .................................................................................................................................. 12 
A. 
Plaintiffs have no claim for breach of contract ...................................... 12 
B. 
Plaintiffs have no claim for equitable estoppel ....................................... 13 
CONCLUSION ................................................................................................................... 14 
 
 
 
 
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TABLE OF AUTHORITIES 
 
Page(s) 
CASES 
In re Avandia Mktg., Sales Practices & Prods. Liab. Litig., 
564 Fed. Appx. 672 (3d Cir. 2014) ............................................................................... 14 
Beukas v. Bd. of Trs. of Fairleigh Dickinson Univ., 
255 N.J. Super. 420 (App. Div. 1992) .......................................................................... 12 
Burcham v. City of Los Angeles, 
No. 2:21-cv-07296-RGK-JPR, 2022 WL 99863 (C.D. Cal. Jan. 7, 
2022) ................................................................................................................................. 11 
Calvary Chapel Dayton Valley v. Sisolak, 
140 S. Ct. 2603 (2020) .......................................................................................................4 
Children’s Health Defense, Inc. v. Rutgers State Univ. of N.J., 
No. 21-15333 (ZNQ), 2021 WL 4398743 (D.N.J. Sept. 27, 2021) .....................passim 
Clapper v. Amnesty Int’l USA, 
568 U.S. 398 (2013) ...........................................................................................................3 
Cruzan v. Director, Missouri Department of Health, 
497 U.S. 261 (1990) ...........................................................................................................7 
F.C.C. v. Beach Comms., Inc., 
508 U.S. 307 (1993) ...........................................................................................................6 
Goldfarb v. Solimine, 
245 N.J. 326 (2021) ......................................................................................................... 13 
Halgren v. City of Naperville, 
No. 21-CV-05039, 2021 WL 5998583 (N.D. Ill. Dec. 19, 2021) .................................3 
Jacobson v. Massachusetts, 
197 U.S. 11 (1905) .....................................................................................................passim 
Johnson v. Brown, 
No. 3:21-CV-1494-SI, 2021 WL 4846060 (D. Or. Oct. 18, 2021) ........................... 12 
Klaassen v. Trs. of Ind. Univ., 
No. 1:21-CV-238 DRL, 2021 WL 3073926 (N.D. Ind. July 18, 2021) ...............passim 
Klaassen v. Trs. of Ind. Univ., 
No. 21-2326, 2022 WL 213329 (7th Cir. Jan. 25, 2022) ...............................................3 
Klaassen v. Trustees of Indiana University, 
7 F.4th 592 (7th Cir. 2021) .......................................................................................passim 
Koontz v. St. John’s River Water Mgmt. Dist., 
570 U.S. 595 (2013) ...........................................................................................................7 
Lorenz c. CSX Corp., 1 F.3d 1406, 1413 (3d Cir. 1993) ..................................................... 14 
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Marbury v. Madison, 
5 U.S. 137 (1803) ................................................................................................................3 
Norris v. Stanley, 
No. 1:21-cv-756, 2021 WL 3891615 (W.D. Mich. Aug. 31, 2021) ........................... 11 
Norwegian Cruise Line Holdings, Ltd. v. Rivkees, 
No. 21-22492-CIV, 2021 WL 3471585 (S.D. Fla. Aug. 8, 2021) .................................8 
Phillips v. City of New York, 
27 F. Supp. 3d 310 (E.D.N.Y. 2014) ...............................................................................8 
Potter v. Newkirk, 
No. 17-08478, 2020 WL 6144756 (D.N.J. Oct. 20, 2020) ................................... 12, 13 
Prudential Ins. Co. of Am v. Bank of Am., Nat’l Ass’n, 
14 F. Supp. 3d 591 (D.N.J. 2014) ................................................................................. 14 
Smith v. Biden, 
No. 1:21-cv-19457, 2021 WL 5195688 (D.N.J. Nov. 8, 2021) ....................................6 
Washington v. Glucksberg, 
521 U.S. 702 (1997) ...........................................................................................................7 
STATUTES, RULES & REGULATIONS 
21 U.S.C. § 360bbb-3(e)(1)(A) ............................................................................................ 11 
N.J.A.C. § 8:57-6.4 ........................................................................................................ 4, 9, 10 
N.J.A.C. § 8:57-6.21.............................................................................................................. 10 
N.J.A.C. § 8.57-6.16.................................................................................................................9 
N.J.S.A. 18A:64M-1 et seq. ......................................................................................................6 
N.J.S.A. § 18A:61D-1 ......................................................................................................... 4, 9 
OTHER AUTHORITIES 
Q&A for Comirnaty (COVID-19 Vaccine mRNA), Food and Drug 
Administration, https://www.fda.gov/vaccines-blood-biologics/qa-
comirnaty-covid-19-vaccine-mrna (last updated Dec. 7, 2021) ................................ 12 
 
 
 
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INTRODUCTION 
The United States and New Jersey Supreme Courts both have held that state 
vaccine mandates do not violate individual constitutional rights.  New Jersey law 
authorizes Rutgers to mandate any vaccine that the federal Advisory Committee on 
Immunization Practices (“ACIP”) has recommended, and the ACIP has strongly 
recommended the COVID-19 vaccines.  Plaintiffs’ opposition (“Opp.”) to Rutgers’ 
motion to dismiss their claims asks this Court not to follow the Supreme Court’s 
controlling decision, not to construe New Jersey law according to its plain terms, and to 
reject the ACIP’s recommendation.  No basis exists for this.  The Court correctly found 
Plaintiffs’ arguments unlikely to succeed when it denied their request for injunctive relief.  
See Children’s Health Defense, Inc. v. Rutgers State Univ. of N.J., No. 21-15333 (ZNQ), 2021 
WL 4398743 (D.N.J. Sept. 27, 2021) (“CHD”).  Nothing has changed. 
For decades, students have had to show evidence of vaccination, or else obtain a 
waiver, as a condition of attendance.  Until now, vaccine requirements had not been 
challenged at Rutgers or any other New Jersey university.  Jacobson v. Massachusetts, 197 U.S. 
11 (1905), which upheld against constitutional challenges a state law mandating 
vaccination without exceptions, has stood the test of time, and in it the Supreme Court 
anticipated and rejected every one of Plaintiffs’ present-day anti-vaccine arguments.  
Plaintiffs challenge the safety and efficacy of the ACIP-recommended COVID-19 
vaccines, just as the Jacobson plaintiff questioned the mandatory smallpox vaccine.  The 
Supreme Court held that states are justified in making mandate decisions based on the 
best scientific evidence available and that they need not defer these decisions until the 
evidence in support is uncontroverted.  And although the Supreme Court has had multiple 
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occasions to revisit Jacobson, including during the COVID pandemic, it has not undermined 
states’ longstanding vaccine mandate authority at all. 
Plaintiffs may disagree with the decisions Rutgers made in the best interests of its 
community during the pandemic, but they have no right to attend Rutgers without 
following the rules.  It does not matter whether Plaintiffs allege claims under the federal 
Constitution (they seem to have dropped their claims under the New Jersey Constitution), 
for “breach of contract,” or for estoppel.  Their claims have no merit, and the Court 
should dismiss the First Amended Complaint (“FAC”) with prejudice. 
ARGUMENT 
I. 
Plaintiffs Misstate The Rights At Issue In Their Case 
Plaintiffs’ brief argued extensively that they “have a constitutionally guaranteed 
right to informed consent and to refuse unwanted medical treatment.”  Opp. at 5.  This is 
not true; the Supreme Court held that the Constitution does not preclude compulsory 
vaccination during a public health crisis.  See Jacobson, 197 U.S. at 24-31.  Regardless, the 
issue in this case is not whether Plaintiffs are free to decline the vaccine, but whether they 
can compel Rutgers to matriculate them if they do so.  They cannot.  As the Seventh 
Circuit noted in Klaassen v. Trustees of Indiana University, 7 F.4th 592, 593 (7th Cir. 2021), 
“vaccination requirements, like other public-health measures, have been common in this 
nation.”  Rutgers has not violated Plaintiffs’ rights by requiring them to be vaccinated, or 
to obtain a waiver, as a condition of attendance. 
A. 
 Jacobson forecloses Plaintiffs’ argument that they have a right to 
attend Rutgers without complying with Rutgers’ vaccination policy 
As this Court already has held, both the setting of this case (a higher education 
vaccine mandate, not compulsory vaccination for the general public), and allowance for 
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religious and medical exemptions, makes Rutgers’ vaccine mandate easier to uphold than 
the law in Jacobson.  See CHD, 2021 WL 4398743, at *5-6.  The Seventh Circuit held the 
same in Klaassen.  When students choose to attend a public university, they agree to 
“surrender property” to do so and, once there, to submit to professors’ instructions to 
“read things they prefer not to read and write things they prefer not to write.”  Klaassen, 7 
F.4th at 593.  The court thus found it “hard to see a greater problem with” a school’s 
imposing “medical conditions that help all students remain safe when learning.”  Id. at 
594.  Further, as also was true in Klaassen, all but one of the Plaintiffs “have claimed the 
religious exemption,”1 and therefore “just need to wear masks and be tested, requirements 
that are not constitutionally problematic.”  Id. at 593.2   
 Plaintiffs call Jacobson “antiquated,” Opp. at 9, referring to its age, but its reasoning 
is no more outdated than Marbury v. Madison, 5 U.S. 137 (1803).  Neither Klaassen nor any 
other court has questioned the core holding of Jacobson that states may mandate vaccines.  
Plaintiffs cite Halgren v. City of Naperville, No. 21-CV-05039, 2021 WL 5998583 (N.D. Ill. 
Dec. 19, 2021), but the Halgren court rebuffed the same arguments that Plaintiffs make 
here.  See id. at *23-33 (declining to apply strict scrutiny and holding that Illinois had a 
                                               
1  Rutgers will not belabor the standing issue because it agrees that “Adriana Pinto has standing to bring 
all claims.”  Opp. at 3.  The Seventh Circuit has dismissed Klaassen as moot because, unlike Ms. Pinto, the 
non-exempt plaintiff in Klaassen conceded that she “ha[s] no plans to return as a student to Indiana 
University” regardless of its vaccination policies.  Klaassen v. Trs. of Ind. Univ., No. 21-2326,2022 WL 
213329, at *1 (7th Cir. Jan. 25, 2022).  Plaintiffs here argue that students who have received religious 
exemptions retain standing to sue because they fear revocation of their exemptions.  See Opp. at 5.  This 
hypothetical does not suffice to confer standing and did not do so in Klaassen.  See id.; see also Clapper v. 
Amnesty Int’l USA, 568 U.S. 398, 409, 416 (2013).   
2  The lower court in Klaassen, like the Seventh Circuit, “decline[d]. . . to expand substantive due process 
rights to include the rights not to wear a mask or to be tested for a virus,” which are “transient and trivial 
inconveniences.”  Klaassen v. Trs. of Ind. Univ., No. 1:21-CV-238 DRL, 2021 WL 3073926, at *39 (N.D. 
Ind. July 18, 2021).  “Indiana University has a legitimate interest in promoting the health and safety of its 
students.  “[M]asks and testing are rationally related” to those interests.  Id. at *40. 
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rational basis to require healthcare workers to take the vaccine).  Plaintiffs also cite Justice 
Alito’s dissent in Calvary Chapel Dayton Valley v. Sisolak, 140 S. Ct. 2603, 2608 (2020), but 
that case did not involve a vaccine mandate.  It addressed special restrictions on worship 
services that the Nevada government did not impose on secular activities, including casino 
gambling. 
B. 
Jacobson held that courts should defer to public health officials on 
questions of vaccines’ safety and efficacy. 
Plaintiffs’ brief trotted out a series of easily debunked anti-vaccine talking points, 
but the inaccuracy of their claims aside, Plaintiffs are wrong about the legal standard 
applicable to their claims.  They contend that Jacobson holds it is for judges to decide if 
vaccines are “safe, efficacious, [and] necessary” before states may mandate them.  Opp. at 
11.  But that is the opposite of what Jacobson held.  Jacobson requires judicial deference to 
rationally-based public health decisions, like mandating an ACIP-recommended vaccine.   
Rutgers in March 2021, like the city of Cambridge in 1902, acted on the “common 
belief . . . that [COVID-19 vaccines] ha[ve] a decided tendency to prevent the spread of 
this fearful disease and to render it less dangerous to those who contract it.”  Jacobson, 197 
U.S. at 34.  Rutgers has every reason to believe that its mandate decision will stand the test 
of time, and the State of New Jersey entrusted Rutgers and other universities the authority 
to mandate ACIP-recommended vaccines.  See N.J.S.A. § 18A:61D-1; N.J.A.C. § 8:57-6.4.  
Plaintiffs here, like the plaintiffs in Jacobson, seek a different policy outcome, seeing “little 
or no value to vaccination as a means of preventing the spread of [COVID-19]” and 
“think[ing] that vaccination causes other diseases of the body.”  Id. at 30.  To the extent 
that Plaintiffs’ contentions amount to a theory on their part that Rutgers should have 
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returned students to campus in Fall 2021 without a vaccine mandate, Jacobson addressed 
this very concept of choosing between a consensus view on one hand and a fringe view 
on the other:  Cambridge then, like Rutgers now, “was not unaware of these opposing 
theories, and was compelled, of necessity, to choose between them.”  Id. at 30.3 
Jacobson’s having placed responsibility for public health decisions in the hands of 
policy-makers and not judges means a courtroom is not a proper forum for Plaintiffs’ 
attempts to cast doubt on the vaccines’ safety and efficacy.  Jacobson held that “[t]he 
possibility that the [common] belief [about safety or efficacy] may be wrong, and that 
science may yet show it to be wrong, is not conclusive.”  Id. at 35.  “With ever evolving 
COVID-19 science, more will be known tomorrow, next month, and next year, but a 
courtroom is no place for guesswork . . . .”  Klaassen, 2021 WL 3073926, at *31.  Plaintiffs’ 
misguided arguments that the ACIP should not have recommended the COVID-19 
vaccine would be better directed to the ACIP or the Centers for Disease Control.   
The Jacobson court made clear that “[i]t is no part of the function of a court or a jury 
to determine which one of two modes”—to mandate a vaccine or to choose another path 
to promote public health—“was likely to be the most effective for the protection of the 
public against disease.”  197 U.S. at 30.  Nor was the Jacobson Court “prepared to hold that 
a minority, residing or remaining in any city or town where [a contagion] is prevalent, and 
enjoying the general protection afforded by an organized local government, may thus defy 
                                               
3  Rutgers cannot allow to go unremarked Plaintiffs’ attempt to rely on the tragic death of a seven-year-
old 
child 
to 
contest 
the 
vaccines’ 
safety. 
 
See 
Opp. 
at 
14 
& 
n.1, 
citing 
https://medalerts.org/vaersdb/findfield.php?IDNUMBER=1975356 (last visited January 17, 2022).  As 
the report states, the child had influenza.  The child had received a COVID-19 vaccine eleven days before 
her death, but nothing in the report suggests that the vaccination caused, contributed to, or had any part 
at all in her death. 
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the will of its constituted authorities, acting in good faith for all, under the legislative 
sanction of the State.”  Id. at 37.4 
This does not mean, and Rutgers does not argue, that the Constitution “permit[s] 
the government to declare a never-ending public emergency and expand its powers 
arbitrarily.”  Klaassen, 2021 WL 3073926, at *22.  Rutgers agrees that “law [and] policy 
should be written with a mindset that medicine and science, and the circumstances that 
they create, will evolve.”  Id.  But in March 2021, Rutgers clearly had a rational basis to 
require students to take an ACIP-recommended COVID-19 vaccination (or to obtain a 
medical or religious exemption) if those students made the decision to return to campus 
for in-person instruction for the Fall 2021 semester.  See Smith v. Biden, No. 1:21-cv-19457, 
2021 WL 5195688 (D.N.J. Nov. 8, 2021) (applying rational basis review to executive orders 
that mandated vaccination for federal employees and contractors).   
As this Court correctly held, Rutgers’ policy bore “a real and substantial relation”  
to its “need to protect public health.”  CHD, 2021 WL 4398743, at *5.  Plaintiffs rightly 
conceded that the purposes of Rutgers’ policy “are legitimate, even compelling state 
interests.”  Opp. at 12.  Plaintiffs’ preference that Rutgers nevertheless should have 
foregone a vaccine mandate in favor of “temperature testing [and] self-administered . . . 
                                               
4  Plaintiffs’ brief referenced their claims that Rutgers has “financial relationships with COVID-19 vaccine 
manufacturers”— principally, Rutgers’ participation as a vaccine trial site, as well as occasional grants 
from pharmaceutical companies—which they say undermine the rational basis for imposing a vaccine 
mandate.  Opp. at 12.  Of course, one of Rutgers’ primary academic missions, as recognized by the 
Legislature, is to conduct scientific research, including clinical trials.  See generally New Jersey Medical and 
Health Sciences Education Act, N.J.S.A. 18A:64M-1 et seq.  Plaintiffs do not plausibly explain how 
Rutgers’ actions to fulfill its purpose as a public research university undermines its interest in protecting 
its students from a contagion by mandating a federally recommended vaccine.  It is Plaintiffs’ “burden to 
negate every conceivable basis that might support” the university’s decision.  See F.C.C. v. Beach Comms., 
Inc., 508 U.S. 307, 307 (1993) (holding under “rational-basis review . . . those attacking [a rule’s] rationality 
have the burden to negate every conceivable basis that might support it”). 
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wellness checks,” Opp. at 17, does not suffice as a basis for judicial reversal of Rutgers’ 
decision.  “This is precisely the debate of medical professionals that state policymakers, 
including authorized arms of the state, are best suited to resolve in setting policy for 
constituents, including here for the students . . . .”  Klaassen, 2021 WL 3073926, at *29. 
C. 
This is not an “unconstitutional conditions” case 
Plaintiffs argue that if they have a constitutional right to refuse a COVID-19 
vaccination (which they do not), Rutgers cannot coerce them to forego that right by 
making it a condition of their matriculation.  See Opp. at 18, citing Koontz v. St. John’s River 
Water Mgmt. Dist., 570 U.S. 595, 604 (2013).  Klaassen considered and rejected this same 
“unconstitutional conditions” argument.  The plaintiffs there, like Plaintiffs here, cited 
Cruzan v. Director, Missouri Department of Health, 497 U.S. 261, 279 (1990), and Washington v. 
Glucksberg, 521 U.S. 702, 720 (1997), both of which addressed the extent of a person’s right 
to refuse lifesaving medical treatment.  Vaccines, by contrast, “address a collective enemy, 
not just an individual one.”  Klaassen, 2021 WL 3073926, at *24.  “A vaccine is implemented 
as a matter of public health, and historically hasn’t been constitutionally deterred from 
state mandate.”  Id., citing Jacobson, 197 U.S. at 30-31.   
“Given over a century’s worth of rulings” rejecting challenges to vaccination 
mandates, not to mention that “the Constitution never provides a fundamental right to a 
collegiate education,” the Klaassen plaintiffs’ unconstitutional conditions argument failed.  
Klaassen, 2021 WL 3073926, at *24.  When universities impose vaccination mandates on 
students who prefer not to be vaccinated, this may “present[] the students with a difficult 
choice” that students may wish to avoid, but they are not “forcing the students to undergo 
injections.”  Id. at 25.  Requiring students who do not wish to be vaccinated to “transfer 
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to a different school, or forego school for the semester or altogether” to avoid vaccination 
“doesn’t amount to coercion.”  Id. 
As in Klaassen, whether Rutgers may mandate vaccines on all students, without 
regard to their religious beliefs, is not at issue.  Rutgers “provides exemptions unlike the 
[law] in Jacobson.”  CHD, 2021 WL 4398743, at *5.  But students who do not qualify for 
exemptions have no right to attend Rutgers without being vaccinated.  If prospective 
students wish not to take a COVID-19 vaccination for reasons other than religious beliefs 
or a medical need, they “‘may go elsewhere’ and seek other educational opportunities.”  Id. 
at *6 (citation omitted).  
D. 
“Unvaccinated” is not a protected class 
Plaintiffs’ Equal Protection Clause claims fail for the simple reason that choosing 
not to be vaccinated does not put one in a legally protected class.  See, e.g., Norwegian Cruise 
Line Holdings, Ltd. v. Rivkees, No. 21-22492-CIV, 2021 WL 3471585, at *14 (S.D. Fla. Aug. 
8, 2021) (“[T]he unvaccinated population is not a protected class that enjoys a fundamental 
Constitutional right to remain unvaccinated.”); Phillips v. City of New York, 27 F. Supp. 3d 
310, 313 (E.D.N.Y. 2014) (same).  Accordingly, the restrictions Rutgers placed on exempt 
and therefore unvaccinated students—i.e., barring them from living communally in 
Rutgers dormitories—are subject only to the rational basis test.  Constant masking is not 
possible in a dormitory setting where hundreds of students are sleeping and using common 
bath facilities in close quarters.  “A university will have trouble operating when each 
student fears that everyone else may be spreading disease.”  Klaassen, 7 F.4th at 594.  
Plaintiffs’ only response in opposing these commonsense measures is to say that the Court 
must assume as true “that COVID-19 is not a vaccine-preventable disease.”  Opp. at 30.  
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The Court need not accept an allegation of purported medical “fact,” however, that 
contradicts the guidance of government at every level. 
II. 
New Jersey Law Empowers Rutgers To Mandate ACIP-Recommended 
Vaccinations, and ACIP Recommended the COVID-19 Vaccines 
N.J.S.A. § 18A:61D-1 obligates Rutgers to require every student to provide proof 
of certain vaccinations.  Beyond an enumerated list of mandatory vaccinations (measles, 
mumps, etc.), the implementing regulation, N.J.A.C. § 8:57-6.4, allows Rutgers “to 
establish additional requirements for student immunizations and documentation that [it] 
shall determine appropriate,” so long as the immunizations are “recommended by the 
ACIP.”  Plaintiffs do not and cannot dispute the ACIP’s strong recommendation, echoed 
by public officials at all levels of government, that every eligible person should become 
vaccinated against COVID-19.  Nothing in the regulation, moreover, distinguishes 
between ACIP-recommended vaccines in Emergency Use Authorization (“EUA”) status 
and those that have received full governmental approval.5 
Plaintiffs ask the Court not to interpret the regulation according to its plain terms.  
They contend the words “establish additional requirements for student immunizations and 
documentation that such institution shall determine appropriate” allow Rutgers only to 
adopt “changes in the types of the documentation that should be accepted as proof of 
vaccination.”  Opp. at 27.  That, however, is not what the plain words of the regulation 
say or mean.  Plaintiffs, moreover, tried this same flawed argument at the preliminary 
                                               
5  Rutgers noted in its opening brief (at 27-28) that N.J.S.A. § 18A:61D-1 and N.J.A.C. § 8.57-6.16 permit 
evidence of natural immunity in lieu of vaccinations only where students can provide “laboratory 
evidence of immunity,” but as of now there exist no approved tests to determine natural immunity or 
protection against COVID-19.  Plaintiffs repeated their argument that Rutgers discriminates against 
students who contend they have natural immunity (see Opp. at 19), but they did not respond to the 
absence of approved tests that would provide legally sufficient “laboratory evidence.” 
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injunction stage.  See ECF No. 24 at 9-11 (“[T]his Court should not be so persuaded that 
a cryptic 30+ year old regulation gave Rutgers and every college in the State, the broad 
and express authority to mandate whatever vaccines they see fit.”).  The Court correctly 
rejected it and should do so again. 
Plaintiffs’ Opp. (at 25-26) cites other laws that authorize the Commissioner of 
Health to mandate vaccines during public health emergencies for the general public and not 
just for university students.  Those statutes are not at issue in this case.  Plaintiffs also cite 
N.J.A.C. § 8:57-6.21, which authorizes the Commissioner to impose additional vaccination 
requirements on higher education students during viral outbreaks and to suspend 
educational vaccine mandates in the event of vaccine shortages.  See Opp. at 26.  Plaintiffs 
appear to contend that because the Commissioner has this authority, the separate 
regulation on which Rutgers relies, N.J.A.C. § 8:57-6.4, cannot have authorized Rutgers to 
mandate vaccines if the Commissioner has not mandated them.  The two regulations, 
however, are not in conflict.  One authorizes the Commissioner not to wait for an ACIP 
recommendation before mandating a vaccine; the other gives narrower authority to 
Rutgers and other institutions of higher education, which may mandate only ACIP-
recommended vaccines.  Nor is there anything incongruous in the State delegating to 
university administrations the same kinds of authority it delegates to “local boards of 
health.”  Opp. at 31.  Universities effectively form their own communities, and in Rutgers’ 
case, that community is quite large. 
Separately, Plaintiffs contend that to the extent the COVID vaccines had only EUA 
status from the Food and Drug Administration at the time Rutgers imposed the mandate, 
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a state law cannot require them to take the vaccine because a federal law, 21 U.S.C. § 
360bbb-3(e)(1)(A), requires the Secretary of Health and Human Services to “establish 
conditions” to inform recipients in writing “of the option to accept or refuse 
administration of the product” and “of the consequences, if any, of refusing 
administration of the product.”  This, too, is a rehash of Plaintiffs’ failed arguments at the 
injunction stage.  See ECF No. 24 at 13-14.  As the court stated in Klaassen, “the informed 
consent requirement under the EUA statute only applies to medical providers,” students 
presumably received “the option to accept or refuse the vaccine [from] their medical 
providers,” and “[t]he university isn’t forcing the students to undergo injections.”  Klaassen, 
2021 WL 3073926, at *25.  The student plaintiffs in Klaassen did not dispute that “before 
the shot reaches their arms, they are made aware of the risks and the option to refuse.”  
Id.  Plaintiffs here do not contend otherwise. 
Further, before Rutgers’ vaccination deadline, the FDA granted full (non-EUA)  
approval to Pfizer’s vaccine.  This moots Plaintiffs’ argument.  See Burcham v. City of Los 
Angeles, No. 2:21-cv-07296-RGK-JPR, 2022 WL 99863, at *8 (C.D. Cal. Jan. 7, 2022) 
(FDA approval of Pfizer vaccine mooted EUA claims); Norris v. Stanley, No. 1:21-cv-756, 
2021 WL 3891615, at *2 (W.D. Mich. Aug. 31, 2021) (same).  Plaintiffs attempt to argue 
that the Pfizer vaccine to which the FDA granted full approval is “not currently available,” 
Opp. at 13, but the FDA’s own “Q&A” debunks this claim.  To the question “How is 
Comirnaty (COVID-19 Vaccine, mRNA) related to the Pfizer-BioNTech COVID-19 
Vaccine?,” the FDA answered that the two formulations “can be used interchangeably 
without presenting any safety or effectiveness concerns” and “providers can use doses 
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distributed under EUA to administer the vaccination series as if the doses were the [fully 
approved] licensed vaccine.”6  See also, e.g., Johnson v. Brown, No. 3:21-CV-1494-SI, 2021 
WL 4846060, at *4-*5 (D. Or. Oct. 18, 2021) (discussing FDA approval of Pfizer vaccine 
and the interchangeability of the EUA formulation and the fully licensed formulation; the 
two are “chemically and biologically identical”). 
III. 
Plaintiffs Have No Claim for Breach of Contract or Equitable Estoppel 
Plaintiffs’ brief gave only cursory attention to their claims that Rutgers contracted 
with them not to mandate the vaccine or else made an extra-contractual promise on which 
Plaintiff Pinto relied to her detriment.  See Opp. at 32-35.  Both claims fail. 
A. 
Plaintiffs have no claim for breach of contract 
Plaintiffs do not seem to contend that a “contract” governing their matriculation 
for the Fall 2021 semester existed prior to March 2021, when Rutgers announced the 
vaccine mandate.  Any plaintiff claiming breach of contract “must, at a minimum, identify 
the contracts and provisions breached.”  Opening Br. at 29, quoting Potter v. Newkirk, No. 
17-08478, 2020 WL 6144756, at *13 (D.N.J. Oct. 20, 2020).  Plaintiffs’ defense of their 
claim posits that “university bulletins” may form part of a contract between a university 
and its students.  Opp. at 32, citing Beukas v. Bd. of Trs. of Fairleigh Dickinson Univ., 255 N.J. 
Super. 420 (App. Div. 1992).  That assertion is wrong, but regardless, Plaintiffs nowhere 
identify any “university bulletin,” or any other document, that is at odds with Rutgers’ 
March 2021 statement that students would not be able to matriculate in August 2021 
without being vaccinated against COVID-19.  “Failure to allege the specific provisions of 
                                               
6 
 
Q&A 
for 
Comirnaty 
(COVID-19 
Vaccine 
mRNA), 
U.S. 
Food 
& 
Drug 
Admin., 
https://www.fda.gov/vaccines-blood-biologics/qa-comirnaty-covid-19-vaccine-mrna 
(last 
updated  
Dec. 7, 2021). 
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the contract breached is grounds for dismissal.”  Potter, 2020 WL 6144756, at *13.  
Plaintiffs find it significant that Rutgers did not state in a pre-pandemic writing to students 
its ability to “alter public health measures as a condition of enrollment.”  Opp. at 33.  As 
noted above, however, state regulations clearly provide for this authority, and Plaintiffs 
again fail to identify any contractual provision prohibiting Rutgers from taking such action. 
B. 
Plaintiffs have no claim for equitable estoppel 
The only plaintiff claiming equitable estoppel is Ms. Pinto.  The Court already 
rejected her claim that she believed she could avoid the mandate by enrolling only in a 
class that the professor chose to conduct remotely.  As the Court wrote in denying 
injunctive relief, “Rutgers defines what constitutes a fully remote student, not Ms. Pinto, 
and she does not meet Rutgers’ definition.”  CHD, 2021 WL 4398743, at *6. 
Ms. Pinto separately tries to rely on statements that Dr. Vicente Gracias made in a 
Rutgers “Our Path Forward” video in January 2021, before any vaccines were available to 
the general public.  Notably, the FAC does not allege that Ms. Pinto saw and relied on this 
video; it alleges only that Plaintiffs Doe 2 and Jessica Moore (who received religious 
objections) saw and relied on it.  See FAC ¶¶ 19, 28.  But, even if Ms. Pinto could allege 
reliance, her characterizations of words on a publicly accessible video are demonstrably 
wrong.  Dr. Gracias stated that “the vaccine at this point is not mandatory across the 
United States or here in New Jersey,” and “is not mandatory at Rutgers.”  Those were 
present-tense statements made in January 2021.  Dr. Gracias made no “clear and definite 
promise” that Rutgers would not mandate the vaccine in the future, as Plaintiffs admit 
they must be able to prove as the first element of an estoppel claim.  Opp. at 33, citing 
Goldfarb v. Solimine, 245 N.J. 326, 339-40 (2021). 
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Further, even if Dr. Gracias had made a clear and definite promise and did so with 
the expectations that students would rely on it in making their Fall 2021 plans (which he 
did not), and even if such reliance would have been reasonable (which it would not have 
been), the fourth element of an estoppel claim is “definite and substantial detriment.”  
Opp. at 33.  The Court need not accept Ms. Pinto’s bare assertion that five months was 
not enough time for her to make other arrangements. 
Just as the Constitution does not preclude Rutgers’ vaccine mandate, neither does 
any contract or extra-contractual promise. 
CONCLUSION 
Rutgers has nearly 70,000 students, and those students nearly unanimously have 
been vaccinated against COVID-19.  This case initially purported to be a well-intentioned 
challenge to Rutgers’ COVID-19 vaccine mandate brought by a handful of Rutgers 
students.  Plaintiffs’ opposition brief dropped the mask, however, demonstrating that this 
case is much more about CHD’s desire to portray all vaccinations as “harm[ful] and 
injur[ious].”  Opp. at 1.  They are wrong, but this Court is not the place for that debate.  
For the foregoing reasons, as well as those stated in Rutgers’ opening brief, the Court 
should put an end to this case once and for all by dismissing Plaintiffs’ First Amended 
Complaint with prejudice.7 
 
 
                                               
7  “Dismissal . . . with prejudice is appropriate if amendment would be inequitable or futile.”  Prudential 
Ins. Co. of Am v. Bank of Am., Nat’l Ass’n, 14 F. Supp. 3d 591, 596 (D.N.J. 2014).  Among the reasons to 
find further amendments futile is “failure to cure deficiencies by amendments previously allowed.”  Lorenz 
c. CSX Corp., 1 F.3d 1406, 1413 (3d Cir. 1993).  “Denial of leave to amend a complaint is especially 
appropriate where a party has already been given the opportunity to amend the complaint.”  In re Avandia 
Mktg., Sales Practices & Prods. Liab. Litig., 564 Fed. Appx. 672, 673 (3d Cir. 2014). 
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Dated: January 31, 2022  
 
 
 
 
 
 
 
 
Respectfully submitted, 
/s/ Jeffrey S. Jacobson  
 
 
 
Jeffrey S. Jacobson  
Andrew B. Joseph 
W. Joshua Lattimore 
Jennifer P. Montan  
FAEGRE DRINKER BIDDLE & REATH 
LLP  
600 Campus Drive 
Florham Park, New Jersey 07932 
(973) 549-7000 
(973) 360-9831 (fax) 
Jeffrey.Jacobson@faegredrinker.com 
Andrew.Joseph@faegredrinker.com 
Joshua.Lattimore@faegredrinker.com 
Jennifer.Montan@faegredrinker.com 
 
Attorneys for Rutgers, The State University of New 
Jersey, et al. 
 
Case 3:21-cv-15333-ZNQ-TJB   Document 43   Filed 01/31/22   Page 19 of 19 PageID: 758

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