Brief - The Eleventh Circuit’s recent decision, Cambridge Christian School, Inc. v. Florida High School (2024-09-23)
- Date
- 2024-09-23
Summary
Plaintiffs' Supplemental Brief Regarding Cambridge Christian, filed September 23, 2024 as Document 143 in Air Force Officer, et al. v. Lloyd J. Austin, III, et al., Case No. 5:22-cv-00009-TES, in the U.S. District Court for the Middle District of Georgia, Macon Division. The brief argues that the Eleventh Circuit's decision in Cambridge Christian School, Inc. v. Florida High School Athletic Ass'n, Inc., No. 22-11222, is distinguishable. It contends that plaintiffs have standing to challenge the Air Force religious accommodation policy itself, relying on Navy SEALs 1-26 v. Austin. It further argues that their claim for declaratory relief on additional COVID-19-vaccine-related restrictions is not moot, reading Cambridge Christian together with Fikre, 601 U.S. 234. The brief is signed by counsel including Thomas More Society attorneys.
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Case 5:22-cv-00009-TES Document 143 Filed 09/23/24 Page 1 of 11
UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
MACON DIVISION
AIR FORCE OFFICER, AIR FORCE NCO, )
AIR FORCE SPECIAL AGENT, and )
AIR FORCE ENGINEER, on behalf of )
themselves and all others similarly situated, )
) Case No. 5:22-cv-00009-TES
Plaintiffs, )
v. )
)
LLOYD J. AUSTIN, III, in his )
official capacity as Secretary of Defense; )
FRANK KENDALL, III, in his )
official capacity as Secretary of the Air Force; and )
ROBERT I. MILLER, in his )
official capacity as Surgeon General of the )
Air Force, )
)
Defendants. )
PLAINTIFFS’ SUPPLEMENTAL BRIEF REGARDING CAMBRIDGE CHRISTIAN
The Eleventh Circuit’s recent decision, Cambridge Christian School, Inc. v. Florida High School
Athletic Ass’n, Inc., 2024 WL 4018866, No. 22-11222 (11th Cir. Sept. 3, 2024), is critically
distinguishable. Unlike in that case, Plaintiffs here have standing to challenge an ongoing policy like
the plaintiffs in Navy SEALs 1-26 v. Austin, No. 4:21-cv-01236-O (N.D. Tex. Feb. 14, 2024) (ECF
262) [Doc. 134-1], and Plaintiffs’ claim for declaratory judgment relating to COVID-19-vaccine-
related restrictions (other than the vaccine mandate itself) is not moot.
The Court’s “standing” analysis in Cambridge Christian—focusing on whether a cognizable
threat of present or future harm is asserted—is relevant to Plaintiffs’ challenge to the
accommodation policy itself and demonstrates how Plaintiffs, like the Navy SEALs plaintiffs and
unlike the school plaintiff in Cambridge Christian, have standing to assert it. The “mootness” analysis
in Cambridge Christian—focusing on the reasonable expectation of reinstatement of a prior policy—is
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relevant to Plaintiffs’ challenge to the additional COVID-19 vaccine restrictions beyond the
mandate itself and demonstrates how Plaintiffs’ claim, unlike the school’s, is not moot.
The present case and Navy SEALs are consistent with and critically distinguishable from
Cambridge Christian. Navy SEALs remains the most on-point case.
A. Plaintiffs have standing to challenge the religious accommodation policy itself.
Unlike the plaintiff school in Cambridge Christian, Plaintiffs here have standing because they
face a substantial and present risk of harm: they are currently hesitant to use the accommodation process
for other religious accommodations.1 Pls. Resp. Br. [Doc. 135] at 2-4; Pls. Declarations [Doc 135-1
through 135-4]; Pls. Reply Br. [Doc. 140] at 2-8. While the school admitted its standing theory relies
on “speculation,” Cambridge Christian, 2024 WL 4018866, at 8, Plaintiffs’ standing here relies on a real
and immediate threat that they would suffer the same harm again, absent judicial relief. Pls. Resp. Br.
at 2-4; Pls. Declarations; Pls. Reply Br. at 2-8. This is not speculation; Plaintiffs are reasonably hesitant
now. Id. See also Navy SEALs, (N.D. Tex. Feb. 14, 2024) (ECF 262 at 8) (“present and future harms”
include those “due to hesitance to use the accommodations process going forward for any religious
accommodation”). Indeed, Plaintiff Air Force NCO retired from service because of his hesitance to use
the accommodation process for any religious accommodation. Declaration of Air Force NCO [Doc.
135-1] at ¶¶ 2-6.
The differences between Cambridge Christian, on the one hand, and the present case (and Navy
SEALs), on the other, are stark. The school’s standing theory depended on its “speculation” that it
might return to the annual state championship football game despite “opt[ing] out” of playoff
1The Air Force has made no assertion that Plaintiffs lack standing to challenge the additional COVID-
19-related restrictions discussed in Section B below. Plaintiffs’ challenge to those restrictions is thus
not subject to any standing analysis under Cambridge Christian. In any event, Plaintiffs can challenge the
additional COVID-19-related restrictions, as discussed in Section B below and in prior briefing.
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competition at least for the current year, a nine-year (and counting) absence from the championship
game, and no imminent prospect of a championship-caliber season for at least the next “few years.”
Cambridge Christian, 2024 WL 4018866, at 8; Cambridge Christian, No. 22-11222 (ECF 89 (the school’s
June 2024 supplemental brief) at 1-2, 2 n.1). The school itself admitted its “standing theory relies on
‘speculation’ that it ‘will make it to another championship game.’” Cambridge Christian, 2024 WL
4018866, at *8.
Further, the school expressly clarified to the Court that it was concerned only with the
defendant athletic association’s specific rule for the one annual championship football game and not
any broader policy that impacted other football games during the season or impacted other sports. Id.
at *7. The Court of Appeals “asked the school to ‘clarify,’” and the school confirmed it was concerned
only with “the football state championship game.” Id. at *7 n.4. Thus, in response to the Court’s
question, the school disavowed any request for relief as to a broader policy. Id. “So we will hold
Cambridge Christian to that answer to our question and to the relief it sought in its complaint.” Id.
By contrast, Plaintiffs here were subject to a vaccine mandate that was rescinded just last year
(Defendant Austin’s 2023 rescission order [Doc. 126-1]), and they continue to be subject to ongoing,
current requirements for which an accommodation can be sought, including for example requirements
to take other vaccines (Air Force Instruction 48-110, Immunizations and Chemoprophylaxis for the Prevention
of Infectious Disease [Doc. 2-9 at 12, 35]), but they are reasonably hesitant to seek such other
accommodations because they reasonably believe the process is illusory and insincere (Pls.
Declarations; Pls. Reply Br. at 2-8). This is a real, present, and non-speculative threat. Navy SEALs 1-
26 (N.D. Tex. Feb. 14, 2024) (ECF 262 at 8-9). Judge O’Connor expressly found the exact same
“hesitance” supported standing. Id. Cf. Speech First, Inc. v. Cartwright, 32 F.4th 1110, 1124 (11th Cir.
2022) (“Because the bias-related-incidents policy objectively chills student speech, Speech First’s
members have standing to challenge it.”) (emphasis added). See also Pls. Resp. Br. at 3-4; Pls. Reply Br.
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at 3-4. There was no issue of “hesitance” in Cambridge Christian.
Unlike in Cambridge Christian, Plaintiffs here challenge a more broadly applicable policy. See
Second Amended Class Action Complaint [Doc. 84], ¶¶ 10, 11, 31, 104-106, 183, 192, 193, 196(a),
196(c), 199, 236, 275, 278; Pls. Op. Br. at 3-10; Pls. Resp. Br. at 2-4; Pls. Declarations; Pls. Reply Br.
at 2-8. Specifically, Plaintiffs challenged the COVID-19 vaccine mandate and also, as relevant here,
challenge the broader accommodation policy itself, just as in Navy SEALs. Id.; Navy SEALs 1-26
(N.D. Tex. Feb. 14, 2024) (ECF 262 at 9, 11-12, 13 n.40, 15, 17). Plaintiffs have “clarified” this in their
declarations and repeatedly in their briefing, consistent with the relief they seek in their complaint and
with Navy SEALs. Pls. Op. Br. at 3-10; Pls. Resp. Br. at 2-4; Pls. Declarations; Pls. Reply Br. at 2-8.
Unlike the school, Plaintiffs here have made clear they challenge a broader policy. Id. This
Court can and should “hold [Plaintiffs] to that.” Cambridge Christian, 2024 WL 4018866, at 7 n.4.
Plaintiffs have standing to challenge the broader accommodation policy itself.
B. Plaintiffs’ claim for declaratory relief regarding additional COVID-19-vaccine-related
restrictions is not moot.
Plaintiffs’ challenge to additional restrictions related to COVID-19 vaccination status (beyond
the 2021 mandate itself2) is not moot under Cambridge Christian.3 There, the Eleventh Circuit did not
address the Supreme Court’s recent affirmation in Fikre that “governmental defendants no less than
[] private ones” maintain a “formidable burden” of showing mootness after voluntarily ceasing a
2
The rescission of the 2021 COVID-19 vaccine mandate was involuntary, unlike the additional
COVID-19-vaccine-related restrictions at issue here. See Pls. Resp. Br. at 4; Pls. Op. Br. at 11-12.
3
The Air Force has made no assertion that it has ever rescinded the sham religious accommodation
process discussed in Section A above. Plaintiffs’ challenge to that that policy is thus not subject to any
mootness / voluntary cessation analysis under Cambridge Christian. See, e.g., Harris v. Georgia Dep’t of
Corr., No. 5:18-CV-00365-TES, 2021 WL 6197108, at *9 (M.D. Ga. Dec. 29, 2021) (plaintiffs still had
standing because of evidence defendants did not terminate some challenged policies and practices and
plaintiffs were still subject to them). In any event, Plaintiffs’ challenge to the process itself remains
viable, as discussed in Section A above and in prior briefing.
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challenged practice. Fikre, 601 U.S. at 241. Cambridge Christian can and should be understood in
harmony with Fikre. Both cases hold that a case is moot only where it’s shown the allegedly wrongful
conduct could not “reasonably be expected to recur.” Cambridge Christian, 2024 WL 4018866, at 9;
Fikre, 60 U.S. at 241. Cambridge Christian recognized that this showing must be “absolutely clear.”
Cambridge Christian, 2024 WL 4018866, at *9.
Even assuming Cambridge Christian requires a presumption of mootness for government
defendants, contrary to Fikre, the presumption is rebutted here, and Cambridge Christian is easily
distinguishable. Unlike the challenged policy in Cambridge Christian, it is not “absolutely clear” COVID-
19 vaccine restrictions are not reasonably likely to recur.
1. Cambridge Christian must be applied in harmony with Fikre, confirming this case
remains live.
In Cambridge Christian, the parties completed original briefing and argument nearly nine months
before the Supreme Court issued Fikre. See Cambridge, No. 22-11222 (June 27, 2023); see Fikre, 601 U.S.
234 (March 19, 2024). And the Court did not mention Fikre in any request for supplemental briefing.
See No. 22-11222, Docs. 88-91. So, while the Eleventh Circuit stated “the Supreme Court has held
almost uniformly that voluntary cessation by a government defendant moots the claim,” Cambridge
Christian, 2024 WL 4019966, at *10 (internal quotes omitted), it did not grapple with Fikre’s recognition
that, as in numerous prior decisions rejecting government assertions of post-voluntary-cessation
mootness, the same “formidable burden” “holds for governmental defendants no less than for private
ones.” Fikre, 601 U.S. at 241 (citing West Virginia v. EPA, 597 U.S. 697, 719 (2022); Trinity Lutheran
Church of Columbia, Inc. v. Comer,582 U.S. 449, 457 n.1 (2017); Parents Involved in Cmty. Schools v. Seattle
School Dist., 551 U.S. 701, 719 (2007)). Indeed, the Eleventh Circuit itself has previously recognized as
much. See Doe v. Wooten, 747 F.3d 1317, 1322 (11th 2014) (“The Supreme Court has applied this same
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standard in cases involving government actors”) (citations omitted). 4
In fact, the Supreme Court has never held or even suggested that government defendants get a
presumption of good faith (and thus a presumption of mootness) after voluntarily ceasing a challenged
practice. Pls. Reply Br. at 12. And Cambridge Christian still recognized that a “defendant’s voluntary
conduct may moot a case only if subsequent events made it absolutely clear that the allegedly wrongful
behavior could not reasonably be expected to recur.” Cambridge, 2024 WL 4018866, at *9 (emphasis
added) (internal quotes omitted). The Supreme Court has long recognized this is a “stringent” burden
even for government defendants. See, e.g., City of Mesquite v. Aladdin’s Castle, 455 U.S. 283, 289 n.10
(1982).
Accordingly, Cambridge Christian can and should be read in harmony with Fikre. Cambridge
Christian holds that “[o]nce a government defendant has repealed a challenged policy, the burden shifts
to the plaintiff to present evidence that its challenge has not been mooted by that repeal.” Id. at *10.
But that test does not relieve the government of its “formidable burden” of showing mootness in
voluntary cessation cases as required by the Supreme Court. See Lopez v. Smith, 574 U.S. 1, 7 (2014)
(“Circuit precedent cannot refine or sharpen a general principle of Supreme Court jurisprudence into
a specific legal rule that this Court has not announced.”) (internal quotes omitted). Thus, the Cambridge
Christian test must be applied in view of the Supreme Court’s “formidable burden” standard in Fikre.5
4
Cambridge Christian also deemed moot the school’s claim for declaratory relief by relying on Preiser v.
Newkirk, 422 U.S. 395, 402 (1975). Cambridge Christian, 2024 WL 4018866, at *9. But Preiser pre-dated
the Supreme Court’s recognition in City of Mesquite that a claim for declaratory relief following the
government’s repeal of the challenged ordinance was not moot even if “the likelihood of further
violations is sufficiently remote to make injunctive relief unnecessary.” City of Mesquite, 455 U.S. at 289 n.10
(emphasis added). See also Pls. Resp. Br. at 5; Pls. Reply Br. at 11-12. City of Mesquite remains good law.
Id.
5
The Air Force has argued that Fikre hinged on government “secrecy inherent in national security
matters.” Air Force Reply Br. [ECF No. 139] at 3. On the contrary (and as noted), Fikre’s “formidable
burden” standard expressly arose from numerous prior precedents applying the same test to
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This approach is not unlike the McDonnell Douglas6 burden-shifting framework in Title VII
cases. Under that framework, even though the burden shifts to the defendant to show a legitimate,
non-discriminatory reason for the challenged action, the plaintiff maintains the ultimate burden of
showing discrimination. See Texas Dep’t of Cmty. Affs. v. Burdine, 450 U.S. 248, 253 (1981) (“The nature
of the burden that shifts to the defendant should be understood in light of the” the fact that “[t]he
ultimate burden . . . remains at all times with the plaintiff.”). So, too, here. While Cambridge Christian
includes its own burden-shifting test, Plaintiffs’ burden must be understood in light of the ultimate
and “formidable burden” that remains with the government defendant. See Fikre, 601 U.S. at 241; see
also id. at 243 (“In all cases, it is the defendant’s burden to establish that it cannot reasonably be expected
to resume its challenged conduct.”) (internal quotes omitted; first and second emphasis added, third
emphasis in original). And here, the Air Force fails to satisfy that “formidable burden” for the reasons
discussed herein and in Plaintiffs’ prior briefing. Pls. Op. Br. at 11-14; Pls. Resp. Br. at 5-6; Pls. Reply
Br. at 12-13.
2. Even assuming a presumption of good faith, Plaintiffs satisfy the Cambridge
Christian burden-shifting factors.
Even if Cambridge Christian is read to require a presumption of mootness in cases involving
voluntary cessation by the government (contrary to Fikre), Plaintiffs’ claim challenging additional
restrictions related to COVID-19 vaccination status remains live. That’s because Plaintiffs have shown
a “reasonable expectation” that the challenged conduct will recur under the “three non-exclusive
factors” considered by Cambridge Christian: “(1) whether the change in conduct resulted from
substantial deliberation . . . ; (2) whether the decision . . . was unambiguous and can be fairly viewed
government defendants even where “secrecy inherent in national security matters” was not at issue. See
Fikre, 601 U.S. at 241-42 (citing cases).
6
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973).
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as being permanent and complete; and (3) whether the government has consistently maintained its
commitment to the new policy.” Cambridge Christian, 2024 WL 4018866, at *10 (internal quotes
omitted) (citing Keohane v. Florida Dep’t of Corr. Sec’y, 952 F.3d 1257, 1268 (11th Cir. 2020)).
All three Cambridge Christian factors strongly favor Plaintiffs. First, there is no evidence of any
deliberation in the Air Force’s rescission of the mandate’s “associated policies and procedures” or in
adopting guidance forbidding commanders “from considering vaccination status for deployment and
assignment-related decisions” on a case-by-case basis. See Pls. Reply Br. at 11 [Doc. 140] (citing Navy
SEALs 1-26 v. Biden, 72 F.4th 666, 671 (2023)).
Instead, following the legally mandated rescission of the mandate itself, Defendant Austin
issued a memorandum stating that “[o]ther standing Departmental policies, procedures, and processes
regarding immunizations remain in effect,” including “the ability of commanders” to discriminate with
respect to “deployment, assignment, and other operational decisions.” [Doc. 126-1 at 3]. Then—
shortly after oral argument before an inquisitive Fifth Circuit panel in Navy SEALs 1-26—Defendant
Austin issued new “guidance” “barr[ing] the military branches . . . from considering vaccination status
for deployment and assignment-related decisions so long as the COVID-19 vaccine remained
optional.” Navy SEALs 1-26, 72 F.4th at 671; see also Nos. 22-10077 and 22-10534 (5th Cir.) (Oral
Argument Heard Feb. 6, 2023, Text Entry No. 161). 7 Defendant Austin’s guidance gave no clear
explanation for the sudden change. See Nos. 22-10077 and 10534 (5th Cir.), Doc. 169 at 9-10.
Second, there is no evidence the Air Force’s change in policy is “unambiguous” or can be
7
While the Fifth Circuit held there was no evidence the Navy adopted its post-rescission policies
“with an eye toward” resumption “as soon as the courts were done,” Navy SEALs 1-26, 72 F.4th at 675
(emphasis added), that is not the test in this Circuit or under Fikre, 601 U.S. at 243 (stating question is
whether “challenged conduct might recur immediately or later at some more propitious moment”) (emphasis
added). See also Pls. Op. Br. at 14; Pls. Resp. Br. at 5.
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“fairly viewed as permanent and complete.” Cambridge Christian, 2024 WL 5018866, at *10. Unlike the
association’s change in Cambridge Christian, no statute here required the Air Force’s rescission of
“associated policies” and optional discrimination. See Cambridge Christian, 2024 WL 4018866, at *11.
Instead, the 2023 National Defense Authorization Act (“NDAA”) specifically required the rescission
only of the Secretary’s “memorandum dated August 24, 2021, regarding ‘Mandatory Coronavirus
Disease 2019 Vaccination of Department of Defense Service Members.’” Navy SEALs 1-26, 72 F.4th
at 671 (quoting Pub. L. No. 117-263, § 525, 136 Stat. 2395, 2571-72 (2022)). The Air Force itself
admits it “went further” and “rescinded more” than what the NDAA required. See Air Force Resp.
Br. [Doc. 136] at 12; accord Navy SEALs 1-26, 72 F.4th at 674 n.7. And no statute prohibits a future
COVID-19 vaccine mandate. Indeed, the Air Force has prevaricated on the possibility of future
restrictions, as Plaintiffs discuss herein and have further detailed in prior briefing. See Pls. Reply Br.
[Doc. 140] at 11. And the Biden Administration officially opposed several proposed provisions of the
2024 NDAA on grounds that it “would prevent the Secretary from taking appropriate action in the
future should a new strain of COVID-19 again require vaccination for force health protection.” 8 That
is hardly “unambiguous” and “permanent” rescission.
Third and finally, and for the same reasons, the Air Force has not “consistently maintained its
commitment to the new policy.” Both the Air Force and the Commander in Chief admit the possibility
of future COVID-19-vaccine-related restrictions. Even if the “likelihood . . . is sufficiently remote to
make injunctive relief unnecessary,” it does not vitiate “the existence of judicial power” to issue a
declaratory judgment. City of Mesquite, 455 U.S. at 289 and n.10.
8
Statement of Administration Policy on H.R. 2670, July 10, 2023, at 5
https://www.whitehouse.gov/wp-content/uploads/2023/07/H.R.-2670-NDAA.pdf (“Statement of
Administration Policy”).
9
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Again, this is nothing like Cambridge Christian. There, “[t]he new law and corresponding policy
. . . mak[e] it clear that the allegedly wrongful conduct . . . cannot reasonably be expected to recur.”
2024 WL 4018866, at *10. Pursuant to and in compliance with a new state statute, the defendant
athletic association “unambiguously” changed its policy, to permit pregame prayer over the PA system
at all state championship football games. Id. at *6, 10-11. The association’s change was made “to
comply with the newly enacted statute.” Id. at *11. There was “no evidence” the change was temporary
or made to manipulate jurisdiction. Id.
By contrast, there is ample evidence here that the change is temporary and was made to
manipulate jurisdiction. The Air Force has prevaricated in asserting its intentions about reinstating
additional restrictions related to the COVID-19 vaccine. Pls. Reply Br. at 10-13. The Air Force has
asserted it “will not” reinstate restrictions and yet admits “there may be” future situations where
“vaccination status will be a consideration” and insists on retaining the right to “maintain its flexibility
to adjust policies” and to “tak[e] appropriate action in the future should a new strain of COVID-19
again require vaccination for force health protection.” Air Force Op. Br. at 17-18; Air Force Resp. Br.
at 14; [Doc. 133-4 at 6]; [Doc. 133-2 at 8]; Statement of Administration Policy; Pls. Reply Br. at 11.
Moreover, the Air Force continues to impose restrictions as to a virus (influenza) that the Air Force
considers to be a less serious threat than COVID-19 while standing on its rights to re-impose
restrictions as to COVID-19. Pls. Resp. Br. at 5-6. Given these prevarications and discrepancies and
the history of the Air Force’s actions, it can very reasonably be expected that the Air Force may resume
its challenged conduct. Plaintiffs’ claim is not moot.
C. Conclusion.
Consistent with Cambridge Christian, Navy SEALs, and Fikre, Plaintiffs have standing to
challenge the religious accommodation policy itself, and Plaintiffs’ claim for declaratory judgment
relating to COVID-19-vaccine-related restrictions is not moot.
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Case 5:22-cv-00009-TES Document 143 Filed 09/23/24 Page 11 of 11
Dated: September 23, 2024
Respectfully submitted,
/s/ Adam S. Hochschild
Stephen Crampton, pro hac vice Michael R. Hirsh, GA #357220
THOMAS MORE SOCIETY – Senior Counsel Hirsh Law Office, LLC
PO Box 4506 2295 Towne Lake Parkway, Suite 116-181
Tupelo, MS 38803 Woodstock, GA 30189
(662)255-9439 (678)653-9907
scrampton@thomasmoresociety.org michael@hirsh.law
Adam S. Hochschild, pro hac vice Mary Catherine Hodes, pro hac vice
Hochschild Law Firm THOMAS MORE SOCIETY – Senior Counsel
THOMAS MORE SOCIETY – Special Counsel 112 S. Hanley Rd., Second Floor
PO Box 401 Clayton, MO 63105
Plainfield, VT 05667 (314)825-5725
(314)503-0326 mchodes@thomasmoresociety.org
adam@hochschildlaw.com
Michael McHale, pro hac vice Paul M. Jonna, pro hac vice
THOMAS MORE SOCIETY – Senior Counsel LiMandri & Jonna LLP
10506 Burt Circle, Ste. 110 THOMAS MORE SOCIETY – Special Counsel
Omaha, NE 63114 P.O. Box 9120
(402)501-8586 Rancho Santa Fe, CA 92067
mmchale@thomasmoresociety.org (858)759-994
pjonna@limandri.com
Counsel for Plaintiffs
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