A Santa Monica College (SMC) freshman, Carter Sparks sued SMC last year claiming the school’s COVID-19 vaccine mandate for in-person learning infringed on his religious freedom and right to privacy. Sparks filed the lawsuit seeking court orders to declare the mandate unconstitutional and beyond the district’s powers, along with injunctive relief and compensatory damages.
The college argued that Sparks did not qualify for a religious exemption, stating that his application did not express a sincerely held religious opposition to vaccination. The college also said that being Catholic does not automatically entitle someone to a religious exemption given the church doesn’t have a prohibition on vaccination.
Sparks had submitted requests for religious and medical exemptions, citing natural immunity from a previous COVID-19 infection, but the college disputed the medical evidence presented in support of his claims.
The court rejected all of Spark’s claims saying he had not shown damages nor had he proven he was treated differently from other students on campus.
Judge Lisa K. Sepe-Wiesenfeld said there was no basis for some of Spark’s claims given the mandate had been rescinded and Sparks was no longer a student. The court also said there was little evidence a mandate would return.
“Several federal circuit courts have examined the issue of whether there is a reasonable expectation that COVID-19-related mandates and policies will be reinstituted, and those courts have concluded there is no reasonable possibility that the alleged violations in those actions will recur because those COVID-19 mandates were rescinded not in response to lawsuits but because of changed circumstances which remain the same since such mandates were rescinded,” said the ruling.
In dismissing the suit, Sepe-Wiesenfeld said Sparks had not shown he was harmed.
“Further, Plaintiff also fails to allege how he was treated differently from other similarly situated persons, providing only a conclusory statement that he ‘was similarly situated to the other students who sought a religious accommodation,’ and he fails to allege the nature of the damages he suffered besides providing a conclusory statement that he ‘suffered damages,’” said the ruling.
“Like institutions of higher education across the country, Santa Monica College adopted a vaccine requirement for students and employees in August 2021,” said a statement provided by SMC. “The court’s decision dismissing the lawsuit is a vindication of the prudent steps taken by the College to respond to an unprecedented global pandemic.”
While the pandemic has ebbed, vaccine mandates remain controversial in parts of the country.
According to a study by the National Academy for State Health Policy, a majority of recent state laws regarding COVID-19 vaccines have focused on the authority of public entities and private businesses to mandate vaccinations.
By the end of 2021, 22 states and Washington, DC, required government employees to be vaccinated or undergo regular testing. Two states banned COVID-19 vaccination mandates for all private employers, while 10 states banned mandates for state workers.
With the end of the public health emergency on May 11, 2023, most states ended COVID-19 vaccination mandates and some are now limiting entities’ ability to require vaccinations. In 2023, several states passed laws restricting governmental and private entities from mandating COVID-19 vaccinations.
Texas, for example, prohibited governmental entities from implementing mandates and allocated no funds for promoting vaccinations. Eleven states limited private businesses from requiring vaccinations.
Legislation expanded beyond employment and access to goods, encompassing areas like adoption and hospital visitation. School-related bills focused on routine vaccination requirements, with some states prohibiting proof of COVID-19 vaccination.
Many states provided exemptions, including medical, religious, and philosophical, with a focus on private businesses. Religious exemptions faced challenges, with some states eliminating them, while others enacted laws requiring religious exemptions for all vaccinations. Overall, state legislation aimed to balance vaccination efforts and limit mandates from public and private entities, necessitating efforts to rebuild trust and engage populations around vaccine-preventable diseases.
matt@smdp.com