Key Orders Elevate Religious Liberty and Constitutional Limits

Washington, DC | December 8, 2025

America’s Frontline Doctors (AFLDS) announced today two consequential actions by the U.S. Supreme Court that sharply escalate judicial scrutiny of coercive vaccine mandates and reaffirm that constitutional limits remain fully operative in times of crisis.

In Miller v. McDonald, the Amish vaccine mandate, the Supreme Court issued a grant, vacate, and remand (GVR) order, directing the lower court to reconsider the case in light of Mahmoud v. Taylor. This action nullifies the prior ruling and compels renewed review under strengthened First Amendment standards governing religious liberty and unconstitutional coercion.

Separately, in Does v. Hochul, a case involving New York healthcare workers terminated under the state’s COVID-19 vaccine mandate, the Supreme Court issued a Call for the Views of the Solicitor General (CVSG). This rare step signals that the Court considers the constitutional questions raised by New York’s mandate regime serious, unresolved, and worthy of heightened scrutiny before deciding whether to grant full review.

In Miller, Amish parents and schools challenge New York’s elimination of religious exemptions to school vaccine requirements. As detailed in AFLDS’s prior amici curiae brief, state officials sought to impose ruinous fines on peaceful religious communities for refusing injections that violate deeply held religious convictions. The Supreme Court’s decision to vacate and remand confirms that such claims cannot be dismissed under diluted constitutional analysis.

In Does, former healthcare workers allege that New York unlawfully revoked religious accommodations and that the lower courts improperly treated the government’s assertion that the COVID shots were “safe and effective” as indisputable fact. AFLDS has consistently maintained that these injections are personal medical treatments, not traditional vaccines, and that the misuse of judicial notice to justify compulsory medical intervention undermines due process, informed consent, and constitutional limits.

“A GVR is not a procedural footnote, it is a directive,” said AFLDS attorney David Dalia. “The Supreme Court wiped away the lower court’s ruling in Miller and ordered reconsideration under controlling First Amendment law. And by calling for the Solicitor General’s views in Does, the Court is openly questioning whether New York’s mandate regime can withstand meaningful constitutional review.”

AFLDS Founder and President Dr. Simone Gold added:

“From the outset of the COVID mandate era, America’s Frontline Doctors fought back in court. In 2021, AFLDS filed many lawsuits to stop unlawful vaccine mandates and to defend healthcare workers threatened with termination for refusing experimental injections. We rejected emergency decrees as law and coercion as consent.

Our rights come from God and are protected by the Constitution. No state has the authority to violate conscience, destroy livelihoods, or force medical compliance. These mandates were unlawful, and they must be judged accordingly.”

These Supreme Court developments build directly on AFLDS’s sustained legal advocacy in both cases and underscore a growing national reckoning with pandemic-era government overreach.

AFLDS will continue to pursue accountability in the courts, defend medical freedom, and restore constitutional boundaries as these cases move forward.

Stay tuned for further updates.

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About AFLDS

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Media Contact Lisa Alexander, Communications Director | Media@AFLDS.org