Jane Doe 1, et al. v. Eric Adams in his official capacity as Mayor of the City of New York, et al.

On Monday, February 7, 2022 the Thomas More Society filed a complaint in the United States District Court in the Eastern District of New York on behalf of six clients who object to vaccination for religious reasons, and who are now unable to participate fully in New York City society due to the “Keys to NYC” executive orders enacted by former Mayor of the City of New York, Bill de Blasio.

These orders forbid unvaccinated members of society from participating in public concerts, dining indoors in public restaurants, and participating in public indoor sporting events. The “Keys to NYC” is being enforced by current Mayor of the City of New York, Eric Adams, and the interim Department of Health and Mental Hygiene Commissioner, defendant Dr. Dave Chokshi, who will serve in that capacity until March 22, 2022, and Dr. Ashwin Vasan, newly appointed Commissioner of the Department of Health and Mental Hygiene of the City of New York, who will succeed Chokshi on March 22, 2022.

Our complaint seeks declaratory and injunctive relief for the resulting deprivations sustained by plaintiffs, and nominal damages for violations committed by the defendants, acting under color of state law, against plaintiffs’ rights as guaranteed by the First, Fifth and Fourteenth Amendments of the United States Constitution.