Supreme Court Declines COVID Mandate Appeal

The U.S. Supreme Court has declined to hear a closely watched challenge to a California COVID-19 vaccine mandate case, leaving in place a Ninth Circuit ruling that critics say grants broad authority to governments imposing medical mandates in the name of public health.

The case, brought by the Health Freedom Defense Fund (HFDF) and California Educators for Medical Freedom, challenged a 2021 COVID-19 vaccine requirement imposed on employees by the Los Angeles Unified School District. Plaintiffs argued the mandate violated constitutional protections involving bodily autonomy and informed consent.

In July 2025, the full Ninth Circuit Court of Appeals ruled against the plaintiffs after rehearing the case en banc. The court held that vaccine mandates tied to public health are subject to a deferential legal standard rooted in the 1905 Supreme Court decision Jacobson v. Massachusetts. Under that standard, judges generally defer to elected officials if authorities could have reasonably believed a policy would protect public health.

The court rejected arguments that the legality of a mandate depends on whether a vaccine fully prevents infection or transmission. According to the ruling, “what reasonable legislative and executive decision makers could have rationally concluded” was more important than later disputes over scientific effectiveness.

After the ruling, the plaintiffs petitioned the Supreme Court to review the case. Court records show the petition was filed in December 2025 under Health Freedom Defense Fund v. Carvalho.

In a statement released after the Supreme Court declined review, HFDF President Leslie Manookian criticized the outcome in stark terms.

“This means that the Ninth Circuit’s egregious ruling — that it doesn’t matter whether a shot stops transmission or infection, all that matters is that a state official could have believed a shot would help individual members of the public — will stand,” Manookian said.

“And it’s now precedent in the largest circuit in the United States.”

Manookian also warned supporters not to expect federal courts to intervene in future mandate disputes.

“But this is the most important thing for us to all take away: the system is not going to protect us,” she said.

“It’s up to us, the people … to refuse to ever obey a mandate from authority again.”

The organization described the ruling as “a massive blow to health freedom” and called the Ninth Circuit decision “one of the most terrifying rulings ever.” HFDF further argued that the court effectively allowed governments to impose medical interventions “with no evidence or judicial review” so long as officials invoke public health concerns.

Legal scholars note, however, that the Ninth Circuit did not eliminate judicial review entirely. Instead, the court applied rational basis review, the most deferential constitutional standard. Under that framework, courts generally uphold laws if officials have a conceivable public-health justification.

The case drew national attention after an earlier three-judge Ninth Circuit panel revived the lawsuit in 2024. That panel suggested the plaintiffs had plausibly alleged that COVID vaccines acted more like treatments that reduce symptoms than traditional sterilizing vaccines that stop spread. The full Ninth Circuit later vacated that opinion and reversed course.

HFDF says it will now focus on State-level legislation aimed at banning medical mandates. The group pointed to Idaho’s recently enacted Medical Freedom Act as a model and said similar proposals are advancing in several other States.

“While I’m incredibly saddened by this, I’m also galvanized,” Manookian said.

Alabama lawmakers have introduced a wave of “medical freedom” and vaccine exemption bills during the 2025 and 2026 legislative sessions, though only a handful gained meaningful traction. Much of the legislation emerged in response to lingering anger over COVID-era vaccine mandates and public health restrictions. In 2025 alone, lawmakers filed bills aimed at expanding religious vaccine exemptions, limiting government promotion of vaccines, protecting organ transplant access regardless of vaccination status, and shielding workers and students from mandate-related penalties.

One of the highest-profile efforts was Senate Bill 85, sponsored by Senators Arthur Orr and Donnie Chesteen. The bill would simplify the process for obtaining religious exemptions from vaccine and testing requirements in schools and colleges. SB85 passed the Alabama Senate in April 2025 by a 26-5 vote and later cleared the House Health Committee, but stalled awaiting a final House vote before the session ended. Meanwhile, House Bills 444 and 503, both sponsored by Representative Mack Butler, sought to broaden vaccine exemptions for private schools, public schools and higher education institutions. Despite support from health freedom advocates, neither bill advanced out of committee before the close of the 2025 session.

Other proposals pushed the debate even further. HB520, the “Alabama Conscientious Right to Refuse Act,” would have barred employers, licensing boards and businesses from discriminating against people who refuse vaccines or other medical interventions on moral or religious grounds. HB367 would have prohibited most State agencies and county health departments from using public funds to advertise or promote vaccines. Neither bill received final committee approval. Lawmakers did achieve one victory tied indirectly to the vaccine debate when Governor Kay Ivey signed SB101 into law in May 2025, raising Alabama’s age of independent medical consent from 14 to 16. Supporters argued the change strengthened parental involvement in medical decisions following disputes during the pandemic over minors receiving vaccines without parental approval.

The movement has remained active in 2026, driven in part by advocacy groups such as Health Freedom Alabama PAC, which has begun issuing endorsements based on candidates’ positions on vaccine mandates and medical choice. While sweeping anti-mandate legislation has repeatedly struggled to survive the legislative process, the issue continues to draw strong support from a vocal bloc of conservative lawmakers and grassroots activists who say they intend to keep pressing the issue in future sessions.

The Supreme Court’s refusal to hear the case does not amount to a ruling on the merits. The justices did not issue an opinion explaining the denial, a common practice when the Court declines review. The effect, however, is that the Ninth Circuit’s ruling remains binding precedent throughout the western states covered by the nation’s largest federal appeals court.