Reply In Support Of Plaintiffs’ Motion
- Date
- 2022-02-28
Summary
A reply in support of plaintiffs' motion for classwide preliminary injunction, filed February 28, 2022 as Document 133 in U.S. Navy SEALs 1-3 et al. v. Lloyd J. Austin, III, Case No. 4:21-cv-01236-O, in the U.S. District Court for the Northern District of Texas. The plaintiffs, Navy servicemembers, argue that the Navy denies every religious accommodation request from the COVID-19 Vaccine Mandate with boilerplate language that does not meet RFRA's compelling interest and least restrictive means test. The reply argues that their claims are ripe and need not be exhausted, that Mindes v. Seaman does not require abstention, and that strict scrutiny rather than military deference applies. It relies on the Fifth Circuit's order in Navy SEALs 1-26 v. Biden, No. 22-10077, and asks the court to set a hearing and grant the classwide injunction.
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Case 4:21-cv-01236-O Document 133 Filed 02/28/22 Page 1 of 13 PageID 4424
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION
U.S. NAVY SEALs 1-3; on behalf of
themselves and all others similarly situated;
U.S. NAVY EXPLOSIVE ORDNANCE
DISPOSAL TECHNICIAN 1, on behalf of
himself and all others similarly situated; U.S.
NAVY SEALS 4-26; U.S. NAVY SPECIAL
WARFARE COMBATANT CRAFT
CREWMEN 1-5; and U.S. NAVY DIVERS
1-3,
Plaintiffs,
Case No. 4:21-cv-01236-O
v.
LLOYD J. AUSTIN, III, in his official
capacity as United States Secretary of Defense;
UNITED STATES DEPARTMENT OF
DEFENSE; CARLOS DEL TORO, in his
official capacity as United States Secretary of
the Navy,
Defendants.
REPLY IN SUPPORT OF PLAINTIFFS’ MOTION
FOR CLASSWIDE PRELIMINARY INJUNCTION
Case 4:21-cv-01236-O Document 133 Filed 02/28/22 Page 2 of 13 PageID 4425
INTRODUCTION
Defendants double down on their claim that the Navy is evaluating each Religious
Accommodation (RA) request as applied to each person. Defendants claim that the Standard
Operating Procedure the Deputy Chief of Naval Operations (DCNO) is using to reject every
request is just a guideline and officials are still doing the requisite evaluation, but all the evidence
indicates the opposite. The picture that continues to emerge is that the Navy seeks to justify its
denial of every Navy servicemember’s RA request by formulaically reciting that “there is no less
restrictive means” and that the Vaccine Mandate “serves the compelling interest of military
readiness and health of the force.” That boilerplate falls far short of what is required under RFRA.
The evidence shows that Defendants do not consider individual circumstances that should
obviously matter, such as whether the servicemember works in an office or with others, in a
dangerous job or a desk job, has special qualifications to train others to make that training safer,
has natural immunity to COVID-19, or has deployed previously without incident. Defendants’
“least restrictive means” analysis is the same for every servicemember. And Defendants’ medical
justification is based on health data that is months old and outdated in light of more recent
developments everyone is aware of. Perhaps realizing this, Defendants argue that the military is
entitled to deference, and that if any review of their decisions is permitted, it should be under the
rational-basis test only. But Defendants’ preferred analysis would require rewriting RFRA, which
neither this Court, nor any other, has the authority to do. Defendants present nothing to explain
why this Court’s conclusion that their evaluation of RA requests is “theater” is incorrect, and
further evidence supports it. The Court should therefore grant the classwide preliminary injunction
1
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to protect the religious-liberty rights of the Navy Class, as it already has done for the 35 individual
Plaintiffs. 1
ARGUMENT
I. Plaintiffs’ Claims Are Justiciable.
A. Defendants’ ripeness arguments are meritless.
This Court already rejected Defendants’ argument that Plaintiffs’ claims are unripe. See
Dkt. 66 at 8–13. Defendants assert that even if Plaintiffs’ appeals of their RA requests are decided,
as some have been now, Plaintiffs’ claims are still unripe until there is a final military decision on
separation. Defendants also refuse to recognize the interim harm Plaintiffs are suffering now. But
the potential harm of being kicked out of the military is only one harm that Plaintiffs suffer. The
immediate harm is the infringement of Plaintiffs’ religious liberty rights, as this Court recognized.
Dkt. 66 at 24. And as the Fifth Circuit just held in denying a stay pending appeal of this Court’s
preliminary injunction, “Plaintiffs . . . face irreparable harm if judicial review is denied. . . . By
pitting their consciences against their livelihoods, the vaccine requirements would crush Plaintiffs’
free exercise of religion.” Navy SEALs 1-26 v. Biden, No. 22-10077 (5th Cir. Feb. 28, 2022), slip
op. at 19.
The military separation process can take years. See App.0040–41. If Defendants were
correct, that would mean that the Navy Class would be forced to suffer the infringement of their
fundamental rights for years before they had any hope of redress. Happily, that is not the law.
1
Other courts have joined this one in granting preliminary injunctions against application
of the DoD vaccine mandate to servicemembers with religious objections. See Poffenbarger v.
Kendall, 3:22-cv-00001-TMR-CHG (S.D. Ohio Feb. 28, 2022); Air Force Officer v. Austin, No.
5:22-cv-00009-TES, 2022 WL 468799 (M.D. Ga. Feb. 15, 2022); Navy SEAL 1 v. Biden, No. 8:21-
cv-2429-sdm-tgw, 2022 WL 520829 (M.D. Fla. Feb. 18, 2022). Requests for class certification
are also pending in Air Force Officer and Navy SEAL 1.
2
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RFRA does not require exhaustion before a plaintiff can seek redress for violation of their statutory
rights, and Fifth Circuit precedent does not require exhaustion where a plaintiff is suffering
irreparable harm and the military administrative procedure is inadequate to remedy that presently
occurring harm, as it is here. Defendants intend to deny every RA request. See App.0003–0004,
0008, 0010. Thus, “Plaintiffs are exempted from exhausting their administrative remedies”
because “the administrative remedy is futile and plaintiffs raise substantial constitutional claims.”
Navy SEALs 1-26, slip op. at 17; see also See Van Hoffburg v. Alexander, 615 F.2d 633, 640 (5th
Cir. 1980). Defendants point to Hodges v. Callaway, 499 F.2d 417 (5th Cir. 1974), but in Hodges,
the only harm at issue was that of wrongful discharge. There was no allegation of ongoing
constitutional or statutory harm. See id. at 419–20. And in any event, Defendants’ own regulations
make clear that any servicemember without an approved religious exemption who refuses COVID-
19 vaccination will be processed for administrative separation. Defendants fail to explain how any
administrative board process could provide relief for any Plaintiff considering those constraints.
Moreover, the military administrative review board process is inadequate for determining
the main issue in this case, which is common to all class members—whether Defendants’ process
for evaluating RA requests comports with RFRA and the First Amendment. See Dkt. 66 at 14
(citing cases).
B. Mindes v. Seaman does not require abstention.
As the Fifth Circuit just held, it is doubtful that Mindes survived RFRA, a super statute.
Navy SEALs 1-26, slip op. at 16. But even if Mindes still applies, it is satisfied here, as this Court
(Dkt. 66 at 8–17) and now the Fifth Circuit have already held, see id. at 18. That does not change
for the Navy Class. Again, “whether denying religious accommodations” across the board
“violates the First Amendment is a distinct legal question that would not ‘seriously impede the
3
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military in the performance of vital duties.’” Dkt. 66 at 16 (quoting Mindes v. Seaman, 453 F.2d
197, 201 (5th Cir. 1971)); see also Dkt. 90 at 5–6 (classwide questions of law and fact). Contrary
to Defendants’ repeated assertions, “[w]hether the vaccine mandate passes muster under the First
Amendment and RFRA requires neither ‘military expertise or discretion.’ It is a purely legal
question appropriate for judicial review.” Dkt. 66 at 16 (quoting Mindes, 453 F.2d at 201). And as
the Fifth Circuit said, “if the Navy’s plan is to ignore RFRA’s protections, as it seems to be on the
record before us, courts must intervene because ‘[g]enerals don’t make good judges—especially
when it comes to nuanced constitutional issues.’” Navy SEALs 1-26, slip op. at 21–22 (quoting Air
Force Officer, 2022 WL 468799, at *8).
II. Strict Scrutiny Applies to the Class Members’ RFRA Claims.
Defendants also claim that any review of their decisions here must be “highly deferential.”
Dkt. 129 at 8–10. But Defendants cite no authority that suggests that a military decision that
violates RFRA is immune from judicial review. In fact, not a single case Defendants cite for that
proposition involves a post-RFRA religious liberty claim. See Trump v. Hawaii, 138 S. Ct. 2392
(2018) (Executive power/Establishment Clause challenge to vetting procedures for immigrants of
foreign states); Solorio v. United States, 483 U.S. 435 (1987) (jurisdiction of a military court-
martial); Goldman v. Weinberger, 475 U.S. 503 (1986) (pre-RFRA Free Exercise claim); Rostker
v. Goldberg, 453 U.S. 57 (1981) (Fifth Amendment Due Process /gender discrimination claim over
sex-based registration for selective service); Fiallo v. Bell, 430 U.S. 787 (1977) (Equal
Protection/Fifth Amendment Due Process challenge to discrimination against fathers of
illegitimate children); Schlesinger v. Ballard, 419 U.S. 498 (1975) (Fifth Amendment Due
Process/gender discrimination challenge to mandatory-discharge provisions); Weiss v. United
States, 510 U.S. 163 (1944) (Appointments Clause /Fifth Amendment Due Process challenge to
appointment of military judges and lack of fixed term of office); Doe 2 v. Shanahan, 755 F. App’x
4
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19 (D.C. Cir. 2019) (Fifth Amendment Due Process challenge to transgender military ban);
Karnoski v. Trump, 926 F. 3d 1180 (9th Cir. 2019) (same).
Defendants’ “doctrine of military deference” cannot rewrite a statute that Congress
intended to apply to the military, nor can this Court. To the contrary, “RFRA provides both broad
protection of the free exercise right and a broad right of action for judicial relief.” Singh v. Carter,
168 F. Supp. 3d 216, 226 (D.D.C. 2016). And “[n]otably, Congress nowhere inserted any
exception for the U.S. Armed Forces from RFRA’s application or any exhaustion requirement, as
it did, for example, in RFRA’s ‘sister statute,’ the Religious Land Use and Institutionalized Persons
Act of 2000 (“RLUIPA”), 42 U.S.C. §§ 2000cc, et seq.” Id. Any deference owed the military “does
not justify the abdication of the responsibility, conferred by Congress, to apply [a statute’s]
rigorous standard.” Holt v. Hobbs, 574 U.S. 352, 364 (2015). “To the contrary, determining
whether a government official’s action contravenes a statutory directive is singularly within the
expertise of a district court.” Navy Seal 1 v. Austin, No. 8:21-CV-2429-SDM-TGW, 2022 WL
534459, at *13 n.7 (M.D. Fla. Feb. 18, 2022) (citing Holt, 574 U.S. at 369 (emphasizing that
RLUIPA “demands much more” than deferring to an officials “mere say-so that they could not
accommodate petitioner’s request”); Harmon v. Brucker, 355 U.S. 579, 582 (1958); Emory v. Sec’y
of Navy, 819 F.2d 291, 294 (D.C. Cir. 1987); Dilley v. Alexander, 603 F.2d 914, 920 (D.C. Cir.
1979) (“It is the duty of the federal courts to inquire whether an action of a military agency
conforms to the law[.]”); Singh, 185 F. Supp. 3d at 218–22; Heap v. Carter, 112 F. Supp. 3d 402
(E.D. Va. 2015)).
III. Defendants’ Boilerplate Denial of Every Religious Accommodation Request Does
Not Satisfy Their High Burden Under RFRA.
“RFRA did more than merely restore the balancing test used in the Sherbert line of cases;
it provided even broader protection for religious liberty than was available under those decisions.”
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Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682, 695 n.3 (2014); accord Holt, 574 U.S. 352,
357 (RFRA “provide[s] greater protection for religious exercise than is available under the First
Amendment.”) Not only does RFRA require that the Government must demonstrate a “compelling
governmental interest” to justify a substantial burden on religious beliefs, but it also requires that
the Government use the “least restrictive means” available for doing so. 42 U.S.C. § 2000bb–1(b).
““[L]east restrictive means’ is a severe form of the ‘narrowly tailored’ test.” McAllen Grace
Brethren Church v. Salazar, 764 F.3d 465, 475 (5th Cir. 2014). It is an “exceptionally demanding”
test for the Government to meet. Id. (citing Hobby Lobby, 134 S. Ct. at 2780). Defendants expect
to meet this demanding test by merely quoting the words “compelling interest” and “least
restrictive means,” but the law requires far more. RFRA requires the “Government to demonstrate
that the compelling interest test is satisfied through application of the challenged law ‘to the
person’ –the particular claimant whose sincere exercise of religion is being substantially
burdened.” Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal, 546 U.S. 418, 430–31
(2006) (quoting 42 U.S.C. § 200bb-1); Hobby Lobby, 573 U.S. at 726. As the Fifth Circuit said,
Defendants’ “institutional interests” here are “nevertheless insufficient under RFRA. The Navy
must instead ‘scrutinize[] the asserted harm of granting specific exemptions to particular religious
claimants.’” Navy SEALs 1-26, slip op. at 24 (quoting O Centro, 546 U.S., at 431).
“RFRA ‘demands much more[]’ than deferring to ‘officials’ mere say-so that they could
not accommodate [a plaintiff’s religious accommodation] request.’” Id. (quoting Holt, 574 U.S. at
369.) A “to the person” analysis under RFRA must be supported by “specific and reliable
evidence” and not “conclusory assertions.” Davila v. Gladden, 777 F.3d 1198, 1206 (11th Cir.
2015) (finding that a prison official’s assertion of a “significant impact on security interests and
cost concerns” was not sufficiently compelling to justify prohibiting a prison inmate from wearing
6
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religious beads and shells); see also Tagore v. United States, 735 F.3d 324, 331 (5th Cir. 2013) (A
“categorical approach” is insufficient, particularly if . . . the statute includes exceptions . . . and the
government must produce evidence justifying its specific conclusion.). The Government must not
rely on “magic words” or “dismissive, encompassing, and inflexible generalizations” to receive
unlimited deference in disputes concerning the military. Navy SEAL 1, 2022 WL 534459 at *15,
*17 (citing Davila, 777 F.3d at 1206). When “military readiness and the health of the force” is
asserted as a compelling interest, the Government must provide “record material demonstrating
that the military considered both the marginal increase, if any, in the risk of contagion incurred by
granting the requested exemption and the marginal detrimental effect, if any, . . . flowing from the
specific denial of [the Plaintiffs’] request for religious exemption from COVID-19 vaccination.”
Navy Seal 1, 2022 WL 534459 at *17. This analysis includes considering the specific skills,
qualifications, and experience levels of the servicemember. Id.
The Navy has yet to provide the evidentiary proof required by RFRA. Instead, the Navy
uses a form denial letter produced by a six-phase, fifty step process that begins with a prepared
disapproval template. App.0012–0030, MPI Hr’g Exs. 11, 19, 24. This form denial, which appears
to be used in adjudicating all requests, vaguely states that the military has a compelling interest in
military readiness, unit cohesion, good order and discipline, health and safety, on both unit and
individual levels. Id. Nowhere in the denial letters does the Navy explain, with any degree of
specificity, why it has a compelling interest in denying a particular RA request. Instead, it relies
on a categorical denial through conclusory assertions unsupported by specific evidence. See Navy
SEALs 1-26, slip op. at 26 (“[I]n none of the letters denying religious accommodations to these
Plaintiffs has the Navy articulated Plaintiff-specific reasons for its decisions.”) “Yet surely, had
the Navy been conscientiously adhering to RFRA, it could have adopted least restrictive means to
7
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accommodate religious objections against forced vaccinations, for instance, to benefit personnel
working from desks, warehouses, or remote locations.” Id. at 27. As this Court already observed,
the Navy’s RA process more closely resembles “theater” than the case-by-case analysis demanded
by RFRA. Dkt. 66 at 1. Defendants claim Plaintiffs’ evidence of a classwide violation of RFRA
is “weak” and disparage the SOP’s original form. Opp. at 15, 17. But this complaint and the SOP
are no longer anonymous. App.0002–0028. Regardless, Defendants do not appear to disavow it.
They simply attempt to downplay it, pretending that it still leaves room for thoughtful
consideration of individual circumstances and least restrictive means analysis to that person.
Additional evidence shows that pretense is false:
First, as the Fifth Circuit explained, “[f]urther evidencing that there is a pattern of disregard
for RFRA rights rather than individualized consideration of Plaintiffs’ requests, the Navy admits
it has not granted a single religious accommodation.” Navy SEALs 1-26, slip op. at 26–27. 2
Second, the denial letters, even outside the NSW community, appear to be nearly identical.
App.0012–0030, 0144–45, MPI Hr’g Exs. 11, 19, 24; see also App.0152, 0156 (Marine).
Third, the Navy appears to use the same “least restrictive means” analysis for every single
person. App.0038, 0043–0056; cf. Opp. at 14 (“The final stage—whether there are any less
restrictive means to achieve the naval interest—is especially individualized.”); Navy SEALs 1-26,
slip op. at 27 (“Yet surely, had the Navy been conscientiously adhering to RFRA, it could have
adopted least restrictive means to accommodate religious objections against forced vaccinations,
for instance, to benefit personnel working from desks, warehouses, or remote locations.”)
2
Defendants now claim that they have approved one RA request but offer no explanation
of this supposed exemption and whether its circumstances comply with RFRA. See Opp. at 16 n.2.
8
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Fourth, the Navy’s analysis for each RA request is simplistic, rote, and involves the same
boilerplate. App.0010, 0026, 0039, 0099–0102; cf. Opp. at 14 (“Each stage is highly dependent on
the particular facts applicable to the individual requestor.”).
Fifth, the Navy refuses to consider changed circumstances in reevaluating requests
submitted several months ago, such as the job of the requestor, newly acquired natural immunity,
and a different variant of COVID-19 which has caused widespread infection in vaccinated
personnel. App.0104–0112, 0125, 0132–0147. Instead, it continues to rely on months-old
information about the virus, even though other agencies have revised health guidelines many times
since last fall. App. 0058–0097, 0113-14.
Sixth, despite all this, the Navy claims the Court should still presume that it is acting in
good faith, even though their actions clearly appear to violate the law. Opp. at 16. Yet DoD has
yet to comply with Congressional requests to explain their review process for RA requests.
App.0152–57.
Mounting evidence shows that that the Court’s original conclusion regarding the Navy’s
RA request process—that it was “by all accounts . . . theater”—is not only correct, but it is correct
for all Navy servicemembers who submitted RA requests and therefore suffer the same harm from
the violation of their rights caused by this process. Dkt. 66 at 1.
IV. Defendants’ Unequal Treatment of Secular and Religious Requests Is Not Neutral,
So Strict Scrutiny Applies to the Navy Class’s First Amendment Claims, Which Are
Likely to Succeed for the Same Reason as the RFRA Claims.
Defendants have granted numerous temporary and permanent medical exemptions to the
Mandate. Yet Defendants claim that their Mandate is still neutral because it applies to everyone.
The Supreme Court disagrees. “A law is not generally applicable if it ‘invite[s]’ the government
to consider the particular reasons for a person’s conduct by providing ‘a mechanism for
individualized exemptions.’” Fulton v. City of Philadelphia, 141 S. Ct. 1868, 1877 (2021)
9
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(citations omitted). “Underinclusiveness mean[s] that” the Mandate is “not generally applicable.”
Id. As the Fifth Circuit concluded, the medical exemptions granted, even to NSW community
members, “renders the vaccine requirements ‘underinclusive.’” Navy SEALs 1-26, slip op. at 26.
Defendants claim that granting medical exemptions, but not religious exemptions, furthers
their interest in maintaining the health of the force, but that is nonsense. “A law also lacks general
applicability if it prohibits religious conduct while permitting secular conduct that undermines the
government's asserted interests in a similar way.” Fulton, 141 S. Ct. at 1877. Even if a
servicemember stands to experience an adverse reaction if they receive the COVID-19 vaccination,
that does not make them less likely to transmit COVID to others than other unvaccinated personnel.
Religious conduct is not more dangerous than the same conduct performed for non-religious
reasons. See Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520, 544–45
(1993). Defendants claimed that the risk of even 35 unvaccinated individual plaintiffs was too
much of a threat to the Navy, see Dkt. 86, yet they have already accepted less than 100%
vaccination by granting medical exemptions.
A law burdening religious practice that is not neutral or not of general application must
undergo the most rigorous of scrutiny. Lukumi, 508 U.S. at 546. Thus, because Defendants’
Mandate is not generally applicable, it is subject to strict scrutiny. It cannot meet that standard for
the same reasons it cannot meet RFRA’s high burden.
CONCLUSION
For these reasons, Plaintiffs respectfully request that the Court set a hearing for Plaintiffs’
motion for class certification and motion for preliminary injunction. The motion for classwide
preliminary injunction should be granted.
10
Case 4:21-cv-01236-O Document 133 Filed 02/28/22 Page 12 of 13 PageID 4435
Respectfully submitted this 28th day of February, 2022.
Kelly J. Shackelford /s/ Heather Gebelin Hacker
Texas Bar No. 18070950 Heather Gebelin Hacker
Jeffrey C. Mateer Texas Bar No. 24103325
Texas Bar No. 13185320 Andrew B. Stephens
Hiram S. Sasser, III Texas Bar No. 24079396
Texas Bar No. 24039157 HACKER STEPHENS LLP
David J. Hacker 108 Wild Basin Road South, Suite 250
Texas Bar No. 24103323 Austin, Texas 78746
Michael D. Berry Tel.: (512) 399-3022
Texas Bar No. 24085835 heather@hackerstephens.com
Justin Butterfield andrew@hackerstephens.com
Texas Bar No. 24062642
Danielle A. Runyan * Attorneys for Plaintiffs
New Jersey Bar No. 027232004
Holly M. Randall *
Oklahoma Bar No. 34763
FIRST LIBERTY INSTITUTE
2001 W. Plano Pkwy., Ste. 1600
Plano, Texas 75075
Tel: (972) 941-4444
jmateer@firstliberty.org
hsasser@firstliberty.org
dhacker@firstliberty.org
mberry@firstliberty.org
jbutterfield@firstliberty.org
drunyan@firstliberty.org
hrandall@firstliberty.org
Jordan E. Pratt
Florida Bar No. 100958* **
FIRST LIBERTY INSTITUTE
227 Pennsylvania Ave., SE
Washington, DC 20003
Tel: (972) 941-4444
jpratt@firstliberty.org
* Admitted pro hac vice
** Not yet admitted to the D.C. Bar, but
admitted to practice law in Florida. Practicing
law in D.C. pursuant to D.C. Court of Appeals
Rule 49(c)(8) under the supervision of an
attorney admitted to the D.C. Bar.
11
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CERTIFICATE OF SERVICE
I hereby certify that on February 28, 2022, I electronically filed the foregoing document
through the Court’s ECF system, which automatically notifies counsel of record for each party.
/s/Heather Gebelin Hacker
HEATHER GEBELIN HACKER
12
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