## Facts

- Indiana University (a public university) adopted a COVID-19 vaccination policy for the Fall 2021 semester applicable to students, faculty, and staff.
- Students who remained unvaccinated without an approved exemption faced consequences including loss of access to campus facilities and suspension of university accounts.
- The policy allowed medical exemptions (including deferrals) and religious exemptions.
- Exempt students were subject to additional requirements such as masking, COVID-19 testing, and social distancing.
- Students had alternatives to vaccination, including seeking an exemption, taking the semester off, attending online, or enrolling elsewhere.
- Eight students sued and sought a preliminary injunction, alleging the policy violated constitutional liberty interests in bodily integrity and refusal of medical treatment.

## Issues

1. Whether the Due Process Clause permits a public university to require COVID-19 vaccination for in-person attendance, subject to medical and religious exemptions.
2. Whether plaintiffs satisfied the requirements for a preliminary injunction, including likelihood of success on the merits and irreparable harm.

## Decision

- The court denied the motion for a preliminary injunction.
- It held plaintiffs were unlikely to succeed on their substantive due process claim because the university’s vaccination requirement was a reasonable public-health measure.
- It found the policy’s exemptions and available alternatives reduced the claim that students were compelled to undergo unwanted medical treatment.
- It concluded the balance of harms and public interest favored allowing the policy to remain in effect to reduce COVID-19 risks in a dense campus setting.

## Legal Principles

- Individuals have a constitutionally protected liberty interest in refusing unwanted medical treatment, but that interest may be subject to reasonable regulation to protect public health.
- Under established vaccination precedent, a state actor may impose a reasonable vaccination requirement consistent with due process.
- Where no fundamental right is infringed, rational-basis review applies; the question is whether the policy rationally advances a legitimate public-health interest.
- A preliminary injunction is an extraordinary remedy requiring, at minimum, a strong showing on likelihood of success, irreparable harm, and that the balance of equities and public interest favor relief.

## Conclusion

The court declined to block Indiana University’s COVID-19 vaccination policy at the preliminary-injunction stage, concluding the requirement—tempered by medical and religious exemptions, additional mitigation measures for exempt students, and practical alternatives—was a constitutionally permissible, rational public-health measure and that equitable factors favored leaving it in place.


Klaassen v. Trs. of Ind. Univ., 549 F. Supp. 3d 836 (N.D. Ind. 2021)