Court upholds dismissal of health workers' vaccination claims

A recent ruling by the U.S. Court of Appeals for the Second Circuit has upheld a lower court's decision to dismiss claims made by a group of health workers against Yale New Haven Health Services Corporation (YNHHS). The plaintiffs, who include Ronda Berens, Dalton Kelly, and others, alleged violations of their rights under the Due Process and Equal Protection Clauses of the Fourteenth Amendment. This ruling is significant as it addresses the legal boundaries of private entities implementing vaccination mandates during public health emergencies.

The case, Berens v. Yale New Haven Health Servs. Corp., docket number 25-3232, arose from the plaintiffs' claims that YNHHS acted under color of state law when enforcing its COVID-19 vaccination policy. The court's decision, issued on October 8, 2026, affirmed the lower court's dismissal of the plaintiffs' claims, stating that they failed to demonstrate a sufficient connection between YNHHS and the state of Connecticut.

Background

The plaintiffs in this case are a group of health care workers employed by YNHHS. They filed their lawsuit after the health system implemented a COVID-19 vaccination mandate, which required employees to be vaccinated or face disciplinary actions, including termination. The plaintiffs argued that this policy violated their constitutional rights.

The case first reached the U.S. District Court for the District of Connecticut, where Judge Janet C. Hall dismissed the plaintiffs' claims on November 26, 2025. The plaintiffs appealed the decision, asserting that the court had erred in its interpretation of their allegations, particularly regarding the claim that YNHHS acted under color of state law.

The Ruling

The Second Circuit, comprising Chief Judge Raymond J. Lohier, Jr., and Circuit Judges Jon O. Newman and Guido Calabresi, ruled in favor of YNHHS. The court found that the plaintiffs did not adequately allege that YNHHS was acting under color of state law, which is a necessary element to establish a claim under 42 U.S.C. § 1983.

The court ruled, "Despite YNHHS’s alleged involvement in the public-private partnership and other collaborative public-health efforts, the SAC does not plead any facts demonstrating Connecticut’s participation in YNHHS’s ultimate adoption, promulgation, and enforcement of its employee vaccination policy."

The court emphasized that simply being involved in public health initiatives does not automatically make a private entity a state actor. The judges noted that the plaintiffs failed to show a close nexus between the state and YNHHS's actions regarding the vaccination policy.

Furthermore, the court addressed the plaintiffs' arguments that the district court had mischaracterized their factual allegations. The judges stated that the lower court was justified in disregarding conclusory allegations that did not provide a factual basis for the claims. The court affirmed the dismissal, stating, "The allegations that the District Court disregarded...are either entirely conclusory or legal conclusions masquerading as alleged facts."

Impact

This ruling has important implications for health care workers and private health organizations. It clarifies the legal standards required to establish that a private entity is acting under color of state law, particularly in the context of public health mandates. The decision indicates that health organizations can implement policies without being deemed state actors, provided they do not have a close enough relationship with the state to warrant such classification.

The ruling may also discourage similar lawsuits by employees challenging vaccination mandates, as it sets a precedent that emphasizes the necessity of proving a direct connection between state action and private entity policies. This decision could influence how other courts handle cases involving vaccination mandates and employee rights in the future.

What's Next

Following this ruling, the plaintiffs have limited options for appeal, as the Second Circuit's decision is typically final unless there are grounds for further review by the U.S. Supreme Court. There are currently no related cases pending that would directly affect this ruling. The outcome may, however, inspire other health care workers facing similar mandates to reconsider their legal strategies.