Pandemic Darlings The pandemic economy, in original documents
Home Court filings Terkel v. Centers for Disease Control and Prevention Defendants' Response to the February 12 Order — Terkel v. CDC

Court filing

Defendants' Response to the February 12 Order — Terkel v. CDC

Filed February 16, 2021 in Terkel v. Centers for Disease Control and Prevention; one of 14 filings from this case.

Record facts

CourtU.S. District Court for the Eastern District of Texas
Filed2021-02-16

U.S. District Court for the Eastern District of Texas · No. 6:20-cv-00564-JCB · Doc. 42 · 2021-02-16 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF TEXAS 
TYLER DIVISION 
 
LAUREN TERKEL, et al., 
 
      Plaintiffs, 
 
v. 
 
CENTERS FOR DISEASE CONTROL AND 
PREVENTION, et al., 
 
      Defendants. 
 
 
 
 
 Case No. 6:20-cv-564-JCB 
 
  
 
 
DEFENDANTS’ RESPONSE TO  
THE COURT’S FEBRUARY 12, 2021 ORDER 
 
 
On February 12, 2021, the Court directed the parties to “file any desired supplemental briefing 
on summary judgment” in light of the Centers for Disease Control and Prevention’s (CDC) extension 
of the Order at issue here, which paused certain residential evictions to prevent the further spread of 
COVID-19.  See ECF No. 41.  As Defendants have explained, although Federal Rule of Civil 
Procedure 56(f) permits a court to consider summary judgment sua sponte, there are good reasons for 
the Court to decline to exercise that discretion here.  See ECF No. 23.  Plaintiffs chose to move for a 
preliminary injunction, and the additional evidence described in the most recent CDC Order confirms 
that this Court should deny Plaintiffs’ motion.  Every court to consider such a motion has denied it, 
including in a case now pending before the Fifth Circuit.  See Chambless Enters., LLC v. Redfield, No. 
20-1455, 2020 WL 7588849 (W.D. La. Dec. 22, 2020), appeal filed, No. 21-30037 (5th Cir. Jan. 21, 2021) 
(plaintiffs’ opening brief due March 22, 2021); Tiger Lily LLC v. U.S. Dep’t of Housing & Urban Dev., --
- F. Supp. 3d ---, No. 20-2692, 2020 WL 7658126 (W.D. Tenn. Nov. 6, 2020); Brown v. Azar, --- F. 
Supp. 3d ---, No. 20-3702, 2020 WL 6364310 (N.D. Ga. Oct. 29, 2020), appeal filed, No. 20-14210 
(11th Cir. Nov. 9, 2020), mot. for inj. pending appeal denied, No. 20-14210 (11th Cir. Dec. 17, 2020); Order, 
Case 6:20-cv-00564-JCB   Document 42   Filed 02/16/21   Page 1 of 6 PageID #:  1519

2 
 
KBW Inv. Props. LLC v. Azar, ECF No. 16, No. 20-4852 (S.D. Ohio Sept. 25, 2020).   
 
Since the completion of briefing on Plaintiffs’ preliminary injunction motion, the CDC Order 
has been extended twice.  On December 27, 2020, President Trump signed into law the Consolidated 
Appropriations Act, 2021, in which Congress voted, by overwhelming majority, to extend the Order 
until January 31, 2021, ratifying CDC’s original action.  See Pub. L. No. 116-260, div. N, tit. V, § 502, 
134 Stat. 1182, 2079 (2020); see also, e.g., United States v. Heinszen & Co., 206 U.S. 370, 384 (1907) 
(holding that Congress “ha[s] power to ratify the acts which it might have authorized” as an initial 
matter).  Just before the expiration of the statutory extension, on January 29, 2021, CDC further 
extended the Order until the end of March 2021.  See Temporary Halt in Residential Evictions to 
Prevent the Further Spread of COVID-19, 86 Fed. Reg. 8020 (Feb. 3, 2021) (the January Order).  The 
January Order is identical in substance and effect to the Order ratified by Congress, but its conclusion 
that a temporary eviction moratorium is necessary to prevent the further spread of COVID-19 is 
supported by additional evidence.  See id. at 8024.  This additional evidence shows that the pandemic 
worsened significantly prior to the issuance of the January Order, id. at 8021, that eviction moratoria 
work to slow the spread of COVID-19, id. at 8022, and that evictions would likely proceed quickly 
and in large numbers were the Order lifted prematurely, potentially increasing COVID-19 spread, id. 
at 8025.   
 
Neither the Supreme Court nor the Fifth Circuit has ever invalidated a regulation of economic 
activity on Commerce Clause grounds, and this case presents no occasion to break new ground.  The 
new data cited in the January Order confirm that the economic activity regulated here—the eviction 
remedy in contracts for rental property—presents a direct and substantial risk of exacerbating the 
interstate spread of COVID-19.  Modeling projections and observational data “indicate that evictions 
substantially contribute to COVID-19 transmission.”  Id. at 8022.  Specifically, preliminary 
mathematical models have found that lifting eviction moratoria led to a 40 percent increased risk of 
Case 6:20-cv-00564-JCB   Document 42   Filed 02/16/21   Page 2 of 6 PageID #:  1520

3 
 
contracting COVID-19 among evicted persons and family or friends with whom they shared housing 
after eviction.  Id.  The same models predicted an increase in overall community transmission even 
among those who did not share housing when evictions occur.  Id.  Further, observational data 
comparing COVID-19 spread in states that lifted eviction moratoria with states that maintained 
eviction moratoria “showed significant increases in COVID-19 incidence and mortality approximately 
2–3 months after eviction moratoria were lifted”—suggesting that, “nationally, over 433,000 cases of 
COVID-19 and over 10,000 deaths could be attributed to lifting state moratoria.”  Id.    
 
Moreover, the January Order provides further evidence that the balance of harms continues 
to heavily favor the government, and that enjoining the CDC Order would be against the public 
interest.  The severity of the pandemic only increased prior to the issuance of the January Order.  As 
that Order points out, December 2020 and January 2021 were the worst months to date in terms of 
COVID-19 new cases and reported deaths.1  Id. at 8021.  The virus has now been detected in every 
county within the continental United States, and new, more contagious strains of the virus are 
spreading throughout the country.  Id.  Newly available scientific evidence has confirmed that evictions 
exacerbate the spread of COVID-19.  Id. at 8022.  And eviction actions continue to be filed during 
the effective period of the Order, indicating that if it were enjoined, a wave of evictions would likely 
result, risking further outbreaks of COVID-19.  Id. at 8025. 
 
At the same time, Congress has now appropriated additional funds for emergency rental 
assistance, for which landlords may apply on behalf of their tenants, and which may be paid directly 
to landlords.  See 2021 Appropriations Act, div. N, tit. V, §§ 501(c)(2), 501(f).  Thus, now more than 
                                                 
1 Although the rate of new infections has slowed in recent weeks, the 7-day moving average of new 
cases on February 15, 2021 was still more than double the 7-day moving average on September 4, 
2020, the day the Order originally went into effect.  See CDC COVID Data Tracker, 
https://covid.cdc.gov/covid-data-tracker/#trends_dailytrendscases (last visited Feb. 16, 2021).  In 
addition, new evidence demonstrates that more COVID-19 infections and deaths would have 
occurred but for eviction moratoria.  See 86 Fed. Reg. at 8022. 
Case 6:20-cv-00564-JCB   Document 42   Filed 02/16/21   Page 3 of 6 PageID #:  1521

4 
 
ever, Plaintiffs’ alleged economic and constitutional injuries “pale[] in comparison to the significant 
loss of life that that Defendants have demonstrated could occur should the Court block the Order.”  
See Brown, 2020 WL 6364310, at *23.  The January Order thus bolsters the conclusion that it is 
unquestionably in the public interest to maintain a temporary eviction moratorium that public health 
experts have confirmed mitigates the spread of a deadly disease in the midst of a once-in-century 
global pandemic. 
 
For these reasons, in addition to those stated in Defendants’ opposition to Plaintiffs’ 
preliminary injunction motion and response to the Court’s November 20, 2020 Order, the Court 
should deny Plaintiffs’ motion.  Furthermore, the additional evidence cited in the January Order—as 
well as the absence of an administrative record with respect to the January Order2—confirm that the 
Court should not address the issue of summary judgment sua sponte. 
Dated:  February 16, 2021 
Respectfully submitted, 
 
BRIAN M. BOYNTON 
Acting Assistant Attorney General 
 
ERIC BECKENHAUER 
Assistant Director, Federal Programs Branch 
 
/s/ Leslie Cooper Vigen            
LESLIE COOPER VIGEN 
Trial Attorney (DC Bar No. 1019782) 
STEVEN A. MYERS 
Senior Trial Counsel (NY Bar No. 4823043) 
United States Department of Justice 
Civil Division, Federal Programs Branch 
1100 L Street, NW 
Washington, DC 20005 
Tel:  (202) 305-0727 
Fax:  (202) 616-8470 
                                                 
2 Defendants are scheduled to supplement the administrative record in a different challenge to the 
CDC Order at issue here on February 22, 2021 to include the new documents CDC considered or 
relied upon in issuing the January Order.  See Minute Order, Ala. Ass’n of Realtors v. U.S. Dep’t of Health 
& Human Servs., No. 20-3377 (D.D.C. Feb. 10, 2021).  Defendants are prepared to likewise supplement 
the administrative record in this action as early as February 22, 2021, should the Court so order. 
Case 6:20-cv-00564-JCB   Document 42   Filed 02/16/21   Page 4 of 6 PageID #:  1522

2 
 
E-mail:  leslie.vigen@usdoj.gov 
 
Counsel for Defendants
Case 6:20-cv-00564-JCB   Document 42   Filed 02/16/21   Page 5 of 6 PageID #:  1523

 
 
CERTIFICATE OF SERVICE 
I hereby certify I served this document today by filing it using the Court’s CM/ECF system, 
which will automatically notify all counsel of record. 
Dated:  February 16, 2021 
 
 
/s/ Leslie Cooper Vigen 
 
Trial Attorney 
 
 
 
Case 6:20-cv-00564-JCB   Document 42   Filed 02/16/21   Page 6 of 6 PageID #:  1524

File and source

File
gov.uscourts.txed.201598.42.0.pdf
Size
144,257 bytes
SHA-256
e8dde1a4f6a1950482400626505d2ebeba18253dc649f10291c2800212756080
Our copy
gov.uscourts.txed.201598.42.0.pdf
Original
archive.org
Back to top