Supreme Court Leaves Ninth Circuit COVID-19 Vaccine Mandate Ruling in Place: What Curtis v. Inslee Means for Employers

June 2, 2026

Employers that adopted or are evaluating mandatory vaccination, testing, or other health-and-safety conditions of employment should take note of the implications of the Supreme Court’s June 1, 2026 decision to deny certification of a Ninth Circuit ruling that narrows the federal claims workers can bring to challenge vaccination requirements.

On June 1, 2026, the U.S. Supreme Court denied the petition for a writ of certiorari in Curtis v. Inslee (Order List, 608 U.S., June 1, 2026), leaving in place the U.S. Court of Appeals for the Ninth Circuit’s published decision in Curtis v. Inslee, No. 24-1869 (9th Cir. Oct. 6, 2025). In Curtis v. Inslee, the Ninth Circuit had rejected the federal claims of more than 80 former employees of a nonprofit health care system who were terminated for refusing COVID-19 vaccination required under Washington State Proclamation 21-14.

Because a denial of certiorari is not a ruling on the merits and sets no nationwide precedent, the practical effect is limited but meaningful: within the Ninth Circuit, the appellate decision stands as controlling authority foreclosing the federal theories the workers advanced. The decision is a useful roadmap of the federal claims that do not lie against employers and government officials who impose vaccination requirements—and, by contrast, a reminder of the claims that may still remain available under other laws.

Background

On August 20, 2021, then-Governor Jay Inslee issued Proclamation 21-14, which, absent an approved exemption, required covered Washington health care workers to be vaccinated against COVID-19. The nonprofit health care system PeaceHealth adopted a corresponding policy, and it terminated employees who refused to comply. Aila Curtis and more than 80 other former at-will employees sued PeaceHealth and the Governor for damages, asserting a wide range of statutory, treaty, regulatory, contractual, and constitutional theories. As the Ninth Circuit summarized, the plaintiffs contended the only vaccine available before the deadline was an “investigational” product authorized only for emergency use, and that they were not adequately informed of an option to refuse it. The U.S. District Court for the Western District of Washington dismissed all claims, and the Ninth Circuit affirmed. See Curtis v. Inslee, No. 24-1869 (9th Cir. Oct. 6, 2025).

No Federal Statutory or “Informed Consent” Right Enforceable Under Section 1983

The court first held that none of the plaintiffs’ statutory and non-constitutional sources created a “specific and definite” right enforceable through 42 U.S.C. § 1983. Central to the workers’ case was the “right to refuse” theory premised on the emergency use authorization provision of the Food, Drug, and Cosmetic Act, 21 U.S.C. § 360bbb-3, which directs that recipients of an emergency-use product be informed of “the option to accept or refuse administration.” The Ninth Circuit explained that Congress confined enforcement of the Act to public actions brought in the name of the United States under 21 U.S.C. § 337(a), and that courts may not judicially create an implied private right of action. The statute therefore confers no privately enforceable right under Section 1983.

The court rejected the remaining non-constitutional sources on the same rationale—none supplied rights-creating language enforceable by these plaintiffs:

  • The Public Readiness and Emergency Preparedness (PREP) Act, 42 U.S.C. § 247d-6, which at most imposes an educational obligation on a federal agency rather than on the employer or the State;
  • 10 U.S.C. § 980 (restricting use of Department of Defense funds for human-subject research), a spending-power provision “especially unlikely” to confer an enforceable right;
  • Article VII of the International Covenant on Civil and Political Rights, which the United States ratified as non-self-executing and which Congress has not implemented;
  • 45 C.F.R. Part 46 (the “Common Rule” on human-subjects research), the Belmont Report, the Federal Wide Assurance agreement, the CDC COVID-19 Vaccination Program Provider Agreement, and the FDA Emergency Use Authorization letters—none of which create privately enforceable rights, and none of which make these employees third-party beneficiaries. As the court observed, the plaintiffs were “vaccine refusers” rather than the “vaccine recipients” who might benefit from such agreements.

Constitutional Claims Foreclosed by Longstanding Vaccination Precedent

Turning to the constitutional theories, the court held that neither the Spending Clause nor the Supremacy Clause supplied a freestanding Section 1983 right. It then rejected the Fourteenth Amendment claims:

  • Substantive due process. The asserted “right to refuse an investigational drug without penalty” was foreclosed by Jacobson v. Massachusetts, 197 U.S. 11 (1905), and the Ninth Circuit’s en banc decision in Health Freedom Defense Fund, Inc. v. Carvalho, 148 F.4th 1020 (9th Cir. 2025) (en banc), under which COVID-19 vaccine mandates are reviewed for a rational basis and upheld where decisionmakers could rationally conclude the mandate protects public health and safety.
  • Procedural due process. The plaintiffs’ at-will employment was not a constitutionally protected property interest, and the proclamation’s notice and individualized religious and medical exemption process supplied any process due.
  • Equal protection. Because the workers did not constitute a suspect class, the mandate needed only survive rational-basis review—which it readily did. The court invoked the Supreme Court’s recognition of the public-health rationale for health care worker vaccination requirements in Biden v. Missouri, 595 U.S. 87 (2022).

State-Law Claims Were Left for the State Courts

Employers should not read the decision as resolving every claim. The Ninth Circuit affirmed dismissal of the state-law claims against the Governor, but it upheld the district court’s discretionary decision to decline supplemental jurisdiction over the remaining state-law contract and tort claims against PeaceHealth under 28 U.S.C. § 1367(c). The court expressly did not decide whether those state-law claims state a claim; it left the merits to the Washington state courts. The federal ruling thus disposes of the federal theories without insulating employers from potential state-law exposure.

What the Cert Denial Does—and Does Not—Mean for Employers

While the Supreme Court’s refusal to review the Ninth Circuit decision in Curtis v. Islee decision for now leaves in place that Court’s ruling that employees don’t havec a federal statutory or informed consent right to challenge vaccination requirements under Section 1983, employers also should keep in mind that these rulings do not mean that vaccination or other health-and-safety mandates are immune from challenge. Rather, Curtis and the now-final disposition confirm that the most commonly asserted federal theories—an implied “right to refuse” under the EUA statute, the PREP Act, and substantive due process—generally do not provide workers a damages remedy against employers or officials for vaccination requirements, at least in the Ninth Circuit. Employers nonetheless should keep the following in mind:

  • Future Supreme Court Decision Could Reach a Different Conclusion. Employers should keep in mind that the Supreme Court’s current decision denying certification does not guarantee it will not take up another case in the future that could reject or qualify the precedent set by the Ninth Circuit. In addition to the continued need to manage these and other potential exposures arising from the establishment and enforcement of vaccination requirements on non-Section 1983 grounds, employers also should use care to avoid engaging in conduct that could create facts that employees might rely upon to charge their employer with retaliation for the employee’s good faith exercise of rights that the employee believed she or he possessed.
  • Other laws still apply. This decision addresses Section 1983, constitutional, and EUA-based theories. It does not displace obligations or exposure under Title VII religious-accommodation and the Americans With Disabilities Act disability-accommodation requirements, the Family and Medical Leave Act and state and local leave laws, state and local civil rights and other laws, or collective bargaining or other contractual requirements. Mandate-related litigation increasingly proceeds on accommodation and contract theories rather than the theories rejected here.
  • Document the exemption and accommodation process. The court emphasized that the proclamation provided notice and an “individualized” religious and medical exemption process. Employers that maintain clear notice, a documented individualized interactive process, and consistent administration are better positioned to defend both constitutional and accommodation challenges.
  • Mind jurisdictional differences. A denial of certiorari leaves circuit law in place without creating a uniform national rule. Multistate employers should confirm how the controlling circuit and applicable state law treat these theories before relying on any single decision.
  • Preserve the public-health record. Rational-basis review turns on what decisionmakers could rationally conclude. Employers adopting health-and-safety requirements should document the legitimate business and safety rationale supporting the requirement at the time it is adopted.

Considering these and other risks, employers using or responding to challenges to employee or service provider vaccination requirements should seek assistance of experience legal counsel in designing and administering those policies to minimize discrimination and retaliation liability risks.

For Help or More Information

The author of this update, Cynthia Marcotte Stamer is an attorney Board Certified in Labor and Employment Law by the Texas Board of Legal Specialization with decades of experience advising and assisting health industry and other employers to design, audit, and defend their employment and other risk management and compliance practices, including conducting audits and investigations, designing and updating compliance and risk management programs, responding to government investigations, conducting transaction, governance, and other due diligence, and assisting with other legal and operational compliance and risk management and legislative and regulatory affairs. She is available to assist your organization in assessing the impact of these developments and navigating the compliance and strategic steps that follow. For more information about these concerns or Ms. Stamer, contact Ms. Stamer via e-mail or via telephone at (214) 452 -8297.

About the Author

Cynthia Marcotte Stamer is an American College of Employee Benefits Counsel and a Martindale-Hubble “AV-Preeminent” (Top 1%) attorney and advisor board certified in labor and employment law by the Texas Board of Legal Specialization peer peer celebrated as “Top Rated Lawyer” and “LEGAL LEADER™ “Top Rated Lawyer” and “Best Lawyer” for her work in ERISA & Employee Benefits Law, Health Care Law, Labor and Employment Law, and Business and Commercial Law.

Nationally recognised for her decades of leading edge workforce, health and other employee benefits and insurance, compensation, regulatory affairs and compliance, and other human resources and other management work, public policy leadership and advocacy, coaching, teachings, and publications, Ms. Stamer’s work throughout her career has focused heavily on working with health care and managed care, health and other employee benefit plan, insurance and financial services and other public and private highly regulated and performance dependent organizations and their technology, data, and other service providers and advisors domestically and internationally with legal and operational compliance and risk management, performance and workforce management, regulatory and public policy and other legal and operational concerns.  As a a key focus of this work, she has continuously and extensively worked with domestic and international health plans, their sponsors, fiduciaries, administrators, and insurers; managed care and insurance organizations on workforce and performance management, employee benefits, compensation, regulatory and operational compliance, and other related concerns.

Her experience includes more than 35 years of leading edge work experience helping health care systems and organizations, group and individual health care providers, government contractors and other performance dependent employers; health plans and insurers, and a broad range of other businesses design and administer workforce, compensation and benefits, compliance and risk management and other practices and policies, and operate and defend organizations and practices to prevent, investigate, manage and resolve performance and behavior; manage civil rights, discrimination and accommodation, and other regulatory, contractual and other compliance responsibilities and risks; vendors and suppliers; conducting and defending investigations, audits, investigations, and other actions; crisis preparedness and response; to establish, administer and defend workforce and staffing, quality, and other compliance, risk management and operational practices, policies and actions; comply with requirements; investigate and respond to Department of Insurance, Board of Medicine, Health, Nursing, Pharmacy, Chiropractic, trucking, alcohol and firearm, and other licensing agencies, Department of Aging & Disability, FDA, Drug Enforcement Agency, OCR Privacy and Civil Rights, Department of Labor, IRS, HHS, DOD, FTC, SEC, CDC and other public health, Department of Justice and state attorneys’ general and other federal and state agencies; JCHO and other accreditation and quality organizations; private litigation and other federal and state health care industry actions: regulatory and public policy advocacy; training and discipline; enforcement;  and other strategic and operational concerns.

Former lead advisor to the Government of Bolivia on its Social Security Privatization reform, Ms. Stamer also has extensive international, federal and state legislative and regulatory affairs experience on federal, state and international workforce, employee benefits, healthcare, education, insurance, data privacy and security, antitrust, and other regulations and reforms.

In addition, Ms. Stamer also is widely celebrated for her leadership in the American Bar Association (“ABA”) and a multitude of other policy, professional, civic, educational, community and other organizations. Ms. Stamer currently or previously served as the the American Bar Association (“ABA”) Joint Committee on Employee Benefits (“JCEB”) leadership council, Scribe leading the Department of Health and Human Services annual agency meeting and a representative to other annual agency meetings, speaker, author and faculty; the ABA International Section International Employment Law Committee and International Life Sciences Committee Chair; the ABA Tort Trial and Insurance Practice Section Medicine and Law Committee Chair, SCOPE member, and Employee Benefits and Worker’s Compensation Committees Vice Chair; the ABA Health Law Section Managed Care & Insurance Interest Group Chair and Risk Management Interest Group Vice Chair; the ABA RPTE Employee Benefits & Other Compensation Group Chair and Welfare Benefit, Fiduciary Responsibility, and Plan Terminations and Transactions Committees Chair; the North Texas Health Care Compliance Professionals Association Vice President and Executive Director; a Southwest Benefits Association Board Member, Treasurer and Continuing Education Committee Chair; a SHRM Consultants National and Region IV Board Chair; a WEB National Board Member and Dallas Chapter President; the National Kidney Foundation of North Texas Board Member and Compliance Chair; the Richardson Development Center (now Warren Center) for Children Early Childhood Intervention Agency Board President; a North Texas United Way Long Range Planning Committee Member; and in many other leadership roles in a broad range of other professional and civic organizations.

Along with these activities, Ms. Stamer also has earned national recognition for her authorship of thousands of highly regarded works, presentations as a knowledgeable speaker, testimony and other input of regulators and legislators, and media interviews on health and other benefits, human resources and other workforce, health care, insurance, data privacy and security and other related concerns. 

For more information about Ms. Stamer or her health industry and other experience and involvements, see www.cynthiastamer.com or contact Ms. Stamer via telephone at (214) 452-8297 or via e-mail here.

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Posted by Cynthia Marcotte Stamer

New California SB 497 90-day Retaliation Presumption Highlights Risk Employers Everywhere Face When Performance Issues Appear Only After Protected Activity

May 19, 2026

California’s SB 497 gives employees a statutory advantage in certain retaliation claims by creating a rebuttable presumption when prohibited employer action occurs within 90 days of protected activity under Labor Code sections 98.6 and 1197.5. California Legislature. For employers everywhere, however, the larger lesson is not limited to California or to a 90-day window. Retaliation claims become harder to defend whenever performance concerns first appear, escalate, or become formally documented only after an employee reports misconduct, complains about unlawful practices, discusses wages, invokes workplace rights, or engages in other protected activity.

SB 497’s New Presumption Changes the Litigation Starting Point in California

SB 497 amended California Labor Code section 98.6 to provide that if an employer takes action prohibited by that section within 90 days of protected activity, “there shall be a rebuttable presumption in favor of the employee’s claim” .California Labor Code section 98.6. Section 98.6 protects employees and applicants from discharge, discrimination, retaliation, or adverse action for exercising specified Labor Code rights, including wage complaints, Labor Commissioner proceedings, and PAGA-related activity California Labor Code section 98.6.

SB 497 also amended Labor Code section 1197.5 to apply a similar 90-day rebuttable presumption to retaliation claims involving equal pay and wage transparency rights. California Labor Code section 1197.5. Section 1197.5 prohibits retaliation against employees for invoking or assisting enforcement of California equal pay rights, and it protects employees who disclose, discuss, or inquire about wages. California Labor Code section 1197.5.

Why Post-Complaint Performance Documentation Is Risky

The most common employer defense to retaliation charges is that the challenged action was based on performance, misconduct, attendance, or business needs. That defense is strongest when the employer can show consistent documentation, prior coaching, objective standards, and comparable treatment of similarly situated employees.

It is much weaker when the record looks different before and after protected activity. If the employee had positive reviews, no written warnings, tolerated deficiencies, or informal coaching before the complaint, and then suddenly receives heightened scrutiny, a PIP, discipline, suspension, or termination afterward, the employee will argue that the employer went looking for a reason to act.

That concern is not theoretical. In Lawson v. PPG Architectural Finishes, Inc., the California Supreme Court shot down the employer’s poor performance defense. The employer cited poor performance and failure to improve under a performance improvement plan, but the California Supreme Court held that Labor Code section 1102.6 governs section 1102.5 whistleblower retaliation claims and does not require the employee to prove the employer’s stated reason was pretextual. Lawson v. PPG Architectural Finishes, Inc. Once the employee shows protected whistleblowing was a contributing factor, the employer must prove by clear and convincing evidence that the same action would have occurred for legitimate, independent reasons even absent the protected activity Lawson v. PPG Architectural Finishes,

The Same Defense Challenge Exists Outside California

Federal law does not generally impose California’s SB 497-style 90-day presumption. Still, timing remains important. The U.S. Supreme Court has recognized that temporal proximity may support causation when it is “very close,” while also holding that an employer need not suspend a previously planned action after learning of protected activity. Clark County School District v. Breeden.

Title VII retaliation claims require proof that retaliation was a but-for cause of the challenged action, not merely a motivating factor. University of Texas Southwestern Medical Center v. Nassar. Even so, close timing, shifting explanations, uneven enforcement, and documentation created only after protected activity can create the factual disputes that make retaliation claims expensive to defend.

Bottom Line for All Employers

California’s 90-day presumption makes covered retaliation claims easier for employees to frame, but it does not create the underlying problem. The real exposure arises when the employer’s performance narrative begins only after protected activity. Employers that want to preserve defensible discipline should build the record before conflict arises, apply standards consistently, and require careful HR and legal review before taking adverse action close in time to protected conduct.

Practical Steps Employers Should Take

Employers do not have to ignore performance issues because an employee complained or engaged in protected activity. They do, however, need to prove that the decision was legitimate, consistent, and independent.

  • Document issues when they happen: Do not wait until after a complaint to document missed deadlines, quality issues, attendance problems, policy violations, or conduct concerns.
  • Audit timing before adverse action: Before discipline, termination, demotion, schedule reduction, compensation changes, or a PIP, check whether the employee recently engaged in protected activity.
  • Separate the complaint process from discipline: Where possible, keep the complaint investigator separate from the performance decisionmaker.
  • Confirm decisionmaker knowledge: Identify who made the decision, what they knew, when they knew it, and what evidence supported the action.
  • Use objective criteria: Tie discipline to measurable standards, written policies, documented expectations, and specific incidents.
  • Compare similar cases: Review how the employer handled similar performance or conduct issues involving employees who did not engage in protected activity.
  • Avoid sudden escalation: If the same issue was tolerated before protected activity, explain and document what changed.
  • Review PIPs carefully: A PIP issued after a complaint should be realistic, job-related, supported by prior evidence, and free from retaliatory tone.
  • Train managers: Supervisors should understand that complaints, wage discussions, whistleblower reports, accommodation requests, safety reports, and participation in investigations may be protected.

If you have questions about or need assistance with these and other risk management or compliance concerns, contact the author. 

For More Information

We hope this update is helpful. For more information about the  or other health or other employee benefits, human resources, or health care developments, please contact the author Cynthia Marcotte Stamer via e-mail or via telephone at (214) 452 -8297.

Solutions Law Press, Inc. invites you receive future updates by registering on our Solutions Law Press, Inc. Website and participating and contributing to the discussions in our Solutions Law Press, Inc. LinkedIn SLP Health Care Risk Management & Operations Group, HR & Benefits Update Compliance Group, and/or Coalition for Responsible Health Care Policy.

About the Author

A Fellow in the American College of Employee Benefits Counsel and Board Certified in Labor and Employment Law by the Texas Board of Legal Certification, Cynthia Marcotte Stamer has more than 35 years experience, advising plan sponsors, fiduciaries, service providers and others about fiduciary responsibility and other employee benefit plan design, administration, risk management and compliance. i

Ms. Stamer is a Martindale-Hubble AV-Preeminent (highest/top 1%) practicing attorney recognized as a “Top Woman Lawyer,” “Top Rated Lawyer,” and “LEGAL LEADER™” in Health Care Law and Labor and Employment Law; among the “Best Lawyers In Dallas” in “Labor & Employment,” “Tax: ERISA & Employee Benefits,” “Health Care” and “Business and Commercial Law for her experience, scholarship, thought leadership and advocacy for 35 plus years of experience advising and representing, employers, employee benefit plans and their fiduciaries and administrators, their administrative services, technology and other business associates and other vendors, managed care and insurance, health care and other clients about these and other workforce, employee benefits, internal controls and other operations and compliance concerns.  

Ms. Stamer is nationally sought out for her decades of leading-edge experience in the design, sponsorship, administration, and defense of workforce, health, severance, savings retirement and other employee benefit, workforce, insurance, healthcare, data and technology, and other operations to promote legal and operational compliance, reduce regulatory and other liability, and advance other operational goals. This experience includes decades of work on ERISA, Internal Revenue Code and other related labor and employment, insurance, corporate and securities, data privacy and security, licensing and other laws. She also sought out for her extensive speaking and publications on these and related concerns.

Along with her decades of legal and strategic consulting experience, Ms. Stamer also contributes her leadership and experience to many professional, civic and community organizations including current or previous service as Employee Benefits Group Chair and a Substantive Groups Committee Member for the ABA Real Property Trusts and Estates (“RPTE”) Section and Chair of its Welfare Plan, Fiduciary Responsibility and Plan Terminations Committees; Chair of the ABA International Section International Employment Law Committee; Chair and Vice Chair of the ABA Tort Trial and Insurance (“TIPS”) Section Medicine and Law Committee, Vice Chair of its Employee Benefits and Worker’s Compensation Committees; and Chair of the ABA Intellectual Property Section Law Practice Management and Special Technologies Committees; ABA Joint Committee on Employee Benefits (“JCEB”) Council Representative and Scribe for its annual agency meetings with the Department of Health and Human Services; International Section Life Sciences Committee Chair; Health Law Section Managed Care & Insurance Interest Group Chair; Vice Chair, Tax Section Fringe Benefit Committee Chair, and in various other ABA leadership capacities. Ms. Stamer also is a former Southwest Benefits Association Board Member and Continuing Education Chair, SHRM National Consultant Board Chair and Region IV Chair, Dallas Bar Association Employee Benefits Committee Chair, former Texas Association of Business State, Regional and Dallas Chapter Chair, a founding board member and Past President of the Alliance for Healthcare Excellence, as well as in the leadership of many other professional, civic and community organizations. She also is valued and celebrated for her decades of policy advocacy and charitable, pro bono, community and other service and leadership to promote understanding and strengthening health care, workforce, saving, disability, aging and retirement and other key policies and challenges through her PROJECT COPE Coalition For Patient Empowerment initiative and many other pro bono service involvements locally, nationally and internationally.

Ms. Stamer is the author of many highly regarded works published by leading professional and business publishers, the ABA, the American Health Lawyers Association, and others. Ms. Stamer also often speaks and serves on the faculty and steering committee for many ABA and other professional and industry conferences and conducts leadership and industry training for a wide range of organizations.

For more information about Ms. Stamer or her health industry, health and other benefits, workforce and other experience and involvements, see the Cynthia Marcotte Stamer P.C. website or contact Ms. Stamer via telephone at (214) 452-8297 or via e-mail here.

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