Kaycee McCoy v. University of Virginia Health System — Memorandum in Support of Injunction

Jeremiah Morgan Circuit Court for the City of Charlottesville, Constitutional Law, Health Law, Litigation

Today, we filed a Memorandum in Support of Injunctive Relief for Kaycee McCoy (see complaint here). After a hearing on the request for a temporary injunction, the Circuit Court requested additional briefing on the temporary injunction factors.

The Memorandum argued that the freedom of religion recognized in Article I, Section 16 of the Virginia Constitution creates a jurisdictional barrier to the State’s COVID-19 vaccine mandate. Furthermore, our Memorandum demonstrated how the vaccine mandate is arbitrary and capricious and is not justified by current COVID-19 conditions. Lastly, our memorandum pokes holes in the prevailing narrative that there are no effective COVID-19 treatments. Moreover, we explain that the three experimental genetic shots being offered under Emergency Use Authorization are neither conventional vaccines, nor “safe and effective.”

Link to Memorandum