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Missouri Edmo 4 21 Cv 01300 8Th 21 3725 Doc 068 Att 0
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Plaintiffs' Response to the Court's August 15, 2023 Show Cause Order, filed August 31, 2023 as Doc. 68 in Missouri v. Biden, No. 4:21-cv-01300-JSD, in the U.S. District Court for the Eastern District of Missouri. The ten plaintiff States argue that the case is not moot after the President issued Executive Order 14099, revoking Executive Order 14042 and its federal contractor COVID-19 vaccination requirement, as of May 12, 2023. The brief recounts the procedural history, including Executive Order 13991, 86 Fed. Reg. 7045, the preliminary injunction entered December 20, 2021 and the Eighth Circuit's dismissal of the government's appeal. It argues that the voluntary-cessation and capable-of-repetition exceptions to mootness apply and asks the court to let the case proceed to judgment. The 15-page filing is signed by a Deputy Solicitor General for the Missouri Attorney General.
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No. 4:21-cv-01300-JSD · Doc. 68 · Docket on CourtListener
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Case: 4:21-cv-01300-JSD Doc. #: 68 Filed: 08/31/23 Page: 1 of 15 PageID #: 1332
IN THE UNITED STATES DISTRICT
COURT FOR THE EASTERN
DISTRICT OF MISSOURI
STATE OF MISSOURI
STATE OF NEBRASKA
STATE OF ALASKA
STATE OF ARKANSAS
STATE OF IOWA No. 4:21-CV-1300
STATE OF MONTANA
STATE OF NEW HAMPSHIRE
STATE OF NORTH DAKOTA
STATE OF SOUTH DAKOTA, and
STATE OF WYOMING,
Plaintiffs,
v.
JOSEPH R. BIDEN, JR.;
et al.
Defendants.
PLAINTIFFS’ RESPONSE TO THE COURT’S AUGUST 15, 2023 SHOW
CAUSE ORDER
INTRODUCTION
This case is not moot. Defendants voluntarily ceased the challenged action,
and the dispute is capable of repetition yet evading review—two of the well-
established exceptions to mootness. Dismissing this case on the ground of mootness
would effectively allow the government to turn on and off the faucet of unlawful
administrative action at will, giving Defendants control over whether or not their
own actions are reviewed by a Court.
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Defendant President Biden signed Executive Order 14042, requiring all
government contractors to ensure their employees were vaccinated against COVID-
19 or to take weekly COVID-19 tests at their own expense. Plaintiff-States
challenged the President's authority to impose such sweeping personal health
requirements—affecting millions of Americans—through the government
contractor regulations. The previously undersigned judge granted a preliminary
injunction prohibiting Defendants from imposing these requirements. During the
Defendant's appeal of that injunction and following an unfavorable decision in the
Fifth Circuit, the Administration revoked EO 14042. Plaintiffs agreed that
Defendants’ appeal before the Eighth Circuit was moot because the preliminary
injunction enjoining the government from enforcing the mandate was no longer
necessary. The fact that an injunction is no longer necessary to prevent harm from
then-ongoing government action, however, does not render the underlying case
moot. Instead, this dispute falls squarely within multiple exceptions to mootness.
Plaintiffs respond to the court’s show-cause order and provide a statement of the
facts and arguments to support their position that proceeding with this case on the
merits is necessary and appropriate.
STATEMENT OF THE FACTS
On January 20, 2021, President Biden (“the President”) signed Executive
Order 13991, 86 Fed. Reg. 7045, which established the Safer Federal Workforce
Task Force (“Task Force”) to provide “ongoing guidance to heads of agencies on the
operation of the Federal Government, the safety of its employees, and the continuity
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of Government functions during the COVID-19 pandemic.” 86 Fed. Reg. at 7046
(§ 4(a)); Missouri v. Biden, 4:21-cv-01300-JSD, Doc. 27. On September 9, 2021, the
President announced that he had signed an “executive order that will require
federal contractors” to be vaccinated. Missouri v. Biden, 4:21-cv-01300-JSD, Doc.
27. The President was referring to Executive Order 14042 ("EO 14042"). EO 14042
further required the Task Force to issue Guidance regarding adequate COVID-19
safeguards. 86 FR 50985.
On September 24, 2021, the Task Force issued Guidance implementing EO
14042. Missouri v. Biden, 4:21-cv-01300-JSD, Doc. 27. The Guidance required
federal contractors ensure that their covered employees were vaccinated against
COVID-19, subject to legal accommodations. Missouri v. Biden, 4:21-cv-01300-JSD,
Doc. 27. Also, on or around September 24, the Acting Director of the Office of
Management and Budget (“OMB”) published in the Federal Register her
determination that the Task Force Guidance will “improve economy and efficiency.”
Missouri v. Biden, 4:21-cv-01300-JSD, Doc. 27.
To implement EO 14042 and the Task Force’s Guidance, as approved by
OMB, the Federal Acquisition Regulatory Council (“FAR Council”) issued a
memorandum on September 30, 2021 to “agencies that award contracts under the
Federal Acquisition Regulation with initial direction for the incorporation of a
clause into their solicitation and contracts to implement” the Guidance. Missouri v.
Biden, 4:21-cv-01300-JSD, Doc. 27.
On November 10, 2021, the Task Force updated the Guidance and changed
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the date contractors’ employees were required to be fully vaccinated from December
8, 2021, to January 18, 2022. Missouri v. Biden, 4:21-cv-01300-JSD, Doc. 27. Also
on November 10, 2021, the Acting Director of OMB filed for publication in the
Federal Register her determination that the updated Guidance “will promote
economy and efficiency in Federal contracting if adhered to by Government
contractors and subcontractors.” Missouri v. Biden, 4:21-cv-01300-JSD, Doc. 27.
According to the Federal Government’s System for Award Management, tens
of billions of dollars of federal contracts feature Plaintiff-States as the place of
performance. Missouri v. Biden, 4:21-cv-01300-JSD, Doc. 27. On October 29, 2021,
Plaintiffs filed the present lawsuit challenging the government’s imposition of the
contractor mandate as, among other things, an unlawful attempt by the federal
government to usurp the States’ police powers and as a violation of multiple
statutory limitations on the government’s authority. Missouri v. Biden, 4:21-cv-
01300-JSD, Doc. 1. On November 4, plaintiffs moved for a preliminary injunction.
Missouri v. Biden, 4:21-cv-01300-JSD, Doc. 8. Defendants filed their response in
opposition on November 18, and plaintiffs filed their reply on November 22, 2021.
Missouri v. Biden, 4:21-cv-01300-JSD, Docs. 20, 23. The parties filed supplemental
briefs on the motion on December 10, 2021. Missouri v. Biden, 4:21-cv-01300-JSD,
Docs. 28, 29. On December 20, 2021, this Court sustained the Plaintiffs’ motion for
preliminary injunction. Missouri v. Biden, 4:21-cv-01300-JSD, Doc. 36.
This court preliminarily enjoined the federal officials from enforcing the
contractor vaccine mandate within the Plaintiff-States after deciding the States
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were likely to prevail on the merits of their claim that EO 14042 exceeded the
President’s authority. Missouri v. Biden, 4:21-cv-01300-DDN, Doc 36. Other federal
courts around the country agreed, with the Fifth Circuit, sitting en banc, affirming
a similar preliminary injunction issued by another district court. See Feds for Med.
Freedom v. Biden, 63 F.4th 366, 387 (5th Cir. 2023). The government appealed this
Court’s order, seeking reversal of this court’s preliminary injunction. Missouri v.
Biden, 22-1104, Doc. 43. After the President issued EO 14099, revoking EO 14042,
Defendants filed an unopposed motion to voluntarily dismiss the appeal, explaining
that the relief they sought from the Eighth Circuit was the reversal or narrowing of
the preliminary injunction barring enforcement of EO 14042. Because Defendants
revoked EO 14042 and the concurrent implementing guidance, the preliminary
injunction challenged on appeal no longer had any effect. Missouri v. Biden, 22-
1104, Doc. 60.
During the pendency of the Defendants’ appeal, the Supreme Court
concluded in another case that a challenge to an “emergency temporary standard”
(ETS) issued by the Occupational Safety and Health Administration (OSHA)
mandating that employers with more than 100 employees require their employees
to undergo COVID-19 vaccination or take weekly COVID-19 tests at their own
expense was likely to succeed on the merits. See Nat'l Fed'n of Indep. Bus. v. Dep't
of Lab., 142 S. Ct. 661, 664 (2022). Consequently, the Supreme Court stayed OSHA’s
rule pending final disposition. Id. at 667. The Court reasoned that the Act, which
empowered the Secretary to set workplace safety standards but not broad public
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health measures, and to issue emergency temporary standards to protect employees
from grave danger in the workplace, did not plainly authorize the ETS. Id. at 666.
On May 9, 2023, the President unilaterally issued Executive Order 14099,
which had the effect of, in part, revoking EO 14042 as of May 12, 2023. See
Executive Order 14099, 88 FR 30891. Following EO 14099, Defendants sought (and
received) Plaintiffs’ consent for Defendants to voluntarily dismiss their appeal of
the preliminary injunction. See Pls.’ Resp. to Unopposed Mot. to Voluntarily
Dismiss Appeal, Missouri v. Biden, 22-1104, at 2 (May 31, 2023). As Plaintiffs
clarified to the Eighth Circuit, however, “while the States do not oppose the
voluntary dismissal of the appeal, they do not agree that the case is moot.” Id. at 2.
As Plaintiffs observed in their response to Defendants’ motion to voluntarily dismiss
the appeal, “the Federal Government has not made any showing that it does not
intend to use the same illegal methods” to either re-instate COVID-19 contractor
vaccine mandates or “use the same illegal methods to implement other health
mandates for federal contractors.” Id. at 2–3. Consequently, Plaintiffs asserted that
the Eighth Circuit “should determine only that the Federal Government has
dismissed its appeal voluntarily, not that the Federal Government has met its
‘heavy burden’ of establishing mootness.” Id. at 2 (citing West Virginia v. EPA, 142
S. Ct. 2587, 2607 (2022)).
The Eighth Circuit agreed. In dismissing Defendants’ appeal of the
preliminary injunction, the court noted that “the only relief from this court
[Plaintiffs] had sought was the reversal or narrowing of the preliminary injunction
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barring enforcement of EO 14042.” Order, Missouri v. Biden, 22-1104, (June 7,
2023) at 3. “Because EO 14042 . . . ‘can no longer be enforced[,]’” the Court concluded
that the government’s requested relief—reversal or narrowing of the preliminary
injunction—can no longer be effectuated and “this appeal has become moot.” Id. At
no point did the Eighth Circuit address whether any aspect of the case besides
Defendants’ appeal of the preliminary injunction order was moot.
On August 15, 2023, this Court issued a Show Cause Order directing
Plaintiffs to show cause why this case should not be dismissed as moot.
ARGUMENT
I. The Doctrine of Mootness and its Exceptions
A federal court has Article III jurisdiction when “an actual controversy” exists
“through all stages of the litigation.” Kingdomware Techs., Inc. v. United States, 579
U.S. 162, 163 (2016) (quoting Already, LLC v. Nike, Inc., 568 U.S. 85, 90–91 (2013)).
For a case to be dismissed as moot, a defendant must carry the burden of showing
that “it can be said with assurance that there is no reasonable expectation that the
alleged violation will recur”; and (2) “interim relief or events have completely and
irrevocably eradicated the effects of the alleged violation.” Cty. of Los Angeles v.
Davis, 440 U.S. 625, 631 (1979). Only then will a court find that “the case is moot
because neither party has a legally cognizable interest in the final determination of
the underlying questions of fact and law.” Id. See also, e.g., City of Erie v. Pap’s
A.M., 529 U.S. 277, 287 (2000) (holding that a case becomes moot “when the
challenged conduct ceases such that ‘there is no reasonable expectation that the
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wrong will be repeated’”) (quoting United States v. W.T. Grant Co., 345 U.S. 629,
633 (1953)).
There are two relevant and closely related exceptions to the doctrine
mootness: (1) voluntary cessation of the challenged activity; and (2) when a wrong
is capable of repetition yet evades review. Northeastern Florida Chapter of
Associated General Contractors of America v. City of Jacksonville, Fla., 508 U.S.
656, 662 (1993) (calling “well settled” the “rule that ‘a defendant’s voluntary
cessation of a challenged practice does not deprive a federal court of its power to
determine the legality of the practice.’”) (quoting City of Mesquite v. Aladdin’s
Castle, Inc., 455 U.S. 283, 289 (1982)); Honig v. Doe, 484 U.S. 305, 318 (1988) (“[The
plaintiff’s] claims . . . are not moot if the conduct he complained of is ‘capable of
repetition, yet evading review.’”) (quoting Murphy v. Hunt, 455 U.S. 478, 482
(1982)). A defendant may not merely stop a particular practice during litigation and
receive automatic dismissal on mootness. The Supreme Court of the United States
has held if there is some likelihood that the practice will continue or resume at a
later date, the litigation is not moot. Roman Cath. Diocese of Brooklyn v. Cuomo,
141 S. Ct. 63, 68 (2020).
Likewise, a government agency or actor may not moot a challenge by merely
changing or discontinuing its challenged policy. An agency may claim that
voluntary cessation moots a challenge only if it is absolutely clear that the behavior
cannot be expected to recur. Parents Involved in Cmty. Schs. v. Seattle Sch. Dist.
No. 1, 551 U.S. 701, 719 (2007) (rejecting a challenge to plaintiff’s standing after
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the public entity “ceased” the challenged policy because “[v]oluntary cessation does
not moot a case or controversy unless ‘subsequent events ma[ke] it absolutely clear
that the allegedly wrongful behavior could not reasonably be expected to recur.’”
(quoting Friends of Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., 528
U.S. 167, 189 (2000)); see also Adarand Constructors, Inc. v. Slater, 528 U.S. 216,
220 (2000) (rejecting an argument that a case is moot after the federal government
changed its policy because “[v]oluntary cessation of challenged conduct moots a case
. . . only if it is ‘absolutely clear that the allegedly wrongful behavior [by the
Defendants] could not be reasonably expected to recur.’” (quoting United States v.
Concentrated Phosphate Export Assn., Inc., 393 U.S. 199, 203 (1968)) (emphasis
added in Adarand)). Importantly, the Supreme Court has held that the fact that a
government has “ceased using” a particular policy or program “is not dispositive” of
the question of whether the case is moot “since the [defendant] vigorously defends
its program’s constitutionality, and nowhere suggests that it will not resume” the
policy or program at a later date. Parents Involved, 551 U.S. at 702.
Similarly, in Roman Catholic Diocese of Brooklyn v. Cuomo, the Supreme
Court held that the Plaintiff's request for an injunction in their action challenging
the New York Governor's Executive Order issued during the COVID-19 pandemic,
limiting attendance at religious services was not moot despite the Governor's
reclassification of areas with COVID-19 restrictions because the Governor regularly
changed classifications of particular areas without prior notice. Roman Cath.
Diocese of Brooklyn, 141 S. Ct. at 68. The Court reasoned that there was “no
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justification" for denying injunctive relief, and the action was clearly not moot. Id.
Similarly, in Federal Election Commission v. Wisconsin Right to Life, Inc., the Court
reasoned that even though the election cycle in question had passed, the cases “fit
comfortably within the established exception to mootness for disputes capable of
repetition, yet evading review” because it would be unreasonable to expect that the
Plaintiffs could have obtained complete judicial review of their claims in time and
it was sufficiently likely that the same controversy would recur in future election
cycles. 551 U.S. 449, 462 (2007). The Court, therefore, held that the passing of the
election cycle did not moot the dispute. Id.
II. Plaintiffs’ case is not moot because each of the exceptions of the
doctrine of mootness apply.
A. This case is not moot because the Defendants voluntarily
ceased the challenged activity.
Like the cases cited above, this case falls squarely within the voluntary
cessation exception to the doctrine of mootness. The Defendants argue that this case
is moot because they have revoked EO 14042. See Executive Order 14099. However,
the Defendants make no assurances that they will not reinstate an identical
unconstitutional and unlawful EO or guidance if the number of COVID-19 cases
were to increase, a new variant emerges, or some other event occurs that the
Defendants deem appropriate to support such a regulation. The voluntary cessation
of a policy does not (and cannot) render a case moot absent any “suggest[ion] that
[Defendants] will not resume” the same policy at a later date. Parents Involved, 551
U.S. at 702.
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In fact, when the Biden administration announced it would be revoking the
EO 14042 vaccine mandate, it also touted the purported “health and safety” benefits
and workplace efficiency of the vaccine requirements.1 The administration went on
to explain that it was removing the requirement because “we are now in a different
phase of our response when these measures are no longer necessary.” Id. However,
this explanation implies that if, in the future, the administration deems we are in
yet another “phase,” it may once again become "necessary" to impose such a
sweeping requirement.
Defendants’ actions, in short, are the axiomatic example of “voluntary
cessation.” Nowhere in EO 14099—or, indeed, any statement by any Defendant—
do Defendants suggest that they will not repeat the same actions again at their
discretion. Indeed, there is nothing stopping Defendants from attempting to
promulgate identical actions tomorrow, next week, or next month. Absent any
“subsequent events” that “ma[ke] it absolutely clear that the allegedly wrongful
behavior could not reasonably be expected to recur,” this case is not moot. Parents
Involved, 551 U.S. at 719. This Court has already once determined that Plaintiffs
are likely to succeed on the merits of their challenges to Defendants actions. The
voluntary cessation exception to the doctrine of mootness prevents litigants from
simply pausing their challenged activities just long enough to defeat receiving an
1 See https://www.whitehouse.gov/briefing-room/statements-
releases/2023/05/01/the-biden-administration-will-end-covid-19-vaccination-
requirements-for-federal-employees-contractors-international-travelers-head-
start-educators-and-cms-certified-facilities (last visited Aug. 30, 2023).
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adverse final judgment. Northeastern Florida Chapter of Associated General
Contractors, 508 U.S. at 662.
B. This case is not moot because Defendants’ actions, if permitted
to be unreviewable, are capable of repetition yet evading
review.
Plaintiffs’ claims remain justiciable for the independent reason that
Defendants’ actions are capable of repetition yet, if permitted to render a case moot,
would evade judicial review. Indeed, the vehicle for Defendants’ unlawful actions—
unilateral and unchecked executive action—is exactly the kind of action that falls
under this exception to the mootness doctrine of being “capable of repetition, yet
evading review” by a Court. Honig, 484 U.S. at 318. The doctrine applies to actions
for which the duration of the action is “too short to be fully litigated prior to its
cessation” and for which there is “a reasonable expectation that the same
complaining party would be subjected to the same action again.” Weinstein v.
Bradford, 423 U.S. 147, 149 (1975).
Defendants began the unlawful actions at issue in this case with a stroke of
the pen when President Biden issued EO 13991 and federal agencies took related
actions. Numerous States and other Plaintiffs challenged these actions, and
multiple federal courts enjoined Defendants’ actions. See, e.g., Feds for Med.
Freedom, 63 F.4th at 387. Then, with another stroke of the pen, Defendants revoked
the executive action—and argued that this second executive action allows them to
avoid final judicial review. Defendants’ sole justification for this second
governmental action was the conclusion that reduction in COVID-19 numbers mean
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that “we no longer need” the challenged action. EO 14099.
Defendants’ behavior, if it is permitted to be used as a tool by Defendants to
avoid judicial review, is exactly the kind of action which falls into the category of
being “capable of repetition.” After Defendants received adverse preliminary
judgments from multiple federal courts, the Biden administration simply
determined that COVID numbers had sufficiently decreased to warrant unilaterally
revoking past executive actions. Given the fluid and ever-changing effects of
COVID-19 and Defendants’ assertion of executive authority to control behavior on
this issue, Defendants could, without warning, over and over again impose and
again remove identical vaccine requirements. Indeed, some news outlets have
recently reported a new surge in COVID-19 numbers.2 Defendants have never
suggested that they would not re-institute their challenged actions at a later date.
Indeed, Defendants are fighting tooth and nail to retain the power to do just
that. On March 23, 2023, the Fifth Circuit, sitting en banc, entered an order
affirming the district court’s grant of a preliminary injunction. If Defendants
believed the executive order entered on May 9, 2023 rendered the matter moot, the
Fifth Circuit’s decision would have little effect. Instead, less than two months ago—
on July 21, 2023—Defendants filed a Petition for Certiorari asking the Supreme
Court to vacate the Fifth Circuit’s decision affirming the preliminary injunction.
See Petition for Certiorari, Joseph R. Biden Jr. v. Feds for Med. Freedom, No. 23-60
2 See, e.g., Julie Bosman, Not Over Yet: Late-Summer Covid Wave Brings Warning
of More to Come, Aug. 28, 2023, https://www.nytimes.com/2023/08/28/us/covid-
cases-hospitalizations.html (last visited Aug. 30, 2023).
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(Jul. 21, 2023).
Defendants’ actions, if allowed to render the case moot, are also capable of
repeatedly evading review. Defendants already once revoked the unlawful actions
in the face of adverse preliminary injunction decisions. This revocation occurred
while several cases were ongoing and occurred before these ongoing cases could
reach a final judgment. Given the unilateral nature of executive actions and the
actions of Defendants challenged in this case, it would be unreasonable to expect
that Plaintiffs could obtain a final judgment the second time that Defendants
attempt the same action.
For these reasons, Defendants have not demonstrated the requisite
permanent policy change, or assurances that they will not reinstate an identical
unconstitutional and unlawful EO or guidance in the future and, therefore, have
not met their burden to show the underlying action is moot.
CONCLUSION
For the foregoing reasons, Defendants have failed to carry their burden of
demonstrating that Plaintiffs’ claims should be dismissed as moot and that neither
of the exceptions to the doctrine of mootness apply to Defendants’ voluntary
cessation of the challenged actions. This Court should allow the case to continue to
judgment.
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Respectfully submitted,
ANDREW BAILEY
Missouri Attorney General
/s/ Maria Lanahan
Maria A. Lanahan, #65956
Deputy Solicitor General
Office of the Attorney General
815 Olive St., Suite 200
St. Louis, MO 63101
(314) 340-4978
(573) 751-0774 (fax)
Maria.Lanahan@ago.mo.gov
Counsel for Plaintiffs
CERTIFICATE OF SERVICE
I hereby certify that, on August 31, 2023, a true and correct copy of the
foregoing and any attachments were filed electronically through the Court’s
CM/ECF system, to be served on counsel for all parties by operation of the Court’s
electronic filing system and to be served on those parties that have not appeared
who will be served in accordance with the Federal Rules of Civil Procedure by mail
or other means agreed to by the party.
/s/ Maria Lanahan
Counsel for Plaintiffs
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