Boone v. Ill. Dept. of Corrections

Plaintiffs-various State of Illinois employees, lacked standing to bring instant lawsuit, alleging that amendment to Health Care T=Right of Conscience Act, which allowed employers to enforce vaccine mandates in workplace to prevent contraction or transmission of COVID-19, violated their federal and state constitutional protections of free exercise of religion and equal protections of laws, under circumstances, where Dist. Ct. agreed with defendants that amendment did not change existing law and merely clarified existing law. Dist. Ct. also found, though, that plaintiffs could proceed with instant lawsuit because issues of fact remained unresolved on very same issues. In instant interlocutory appeal, Ct. of Appeals found that plaintiffs lacked standing to bring instant lawsuit once Dist. Ct. found that amendment did not change exiting law, since: (1) once Dist. Ct. found that amendment only clarified existing law, plaintiff could not show any harm flowing from enactment of amendment so as to support their standing to bring instant lawsuit; and (2) no harm, therefore, could be remedied by striking instant amendment. Thus, remand was required with directions to Dist. Ct. to dismiss instant lawsuit due to plaintiffs’ lack of standing.