Gaining Ground Against COVID Tyranny

Washington, DC - June 9, 2025

On June 4, 2025, Dr. Simone Gold and the AFLDS legal team filed an amici curiae brief with the Supreme Court of the United States in support of the Petitioners in Does v. Hochul, 24-1015. The Petitioners in this case are former healthcare workers in the state of New York. The Respondents are New York Governor Kathy Hochul, Commissioner of the New York State Department of Health James McDonald, Trinity Health, New-York Presbyterian Healthcare System, and Westchester Medical Center Advanced Physician Services. By submitting a petition for writ of certiorari to SCOTUS, the Petitioners are asking the High Court to reverse the decision of the U.S. Second Circuit Court of Appeals - seeking declaratory relief and damages resulting from the state’s COVID “vaccine” mandate.

In 2021, the state of New York issued a mandate requiring healthcare workers to be fully vaccinated against COVID-19 as a condition of continued employment. Though initially offering religious accommodations, the state subsequently revoked them. In short, the state’s mandate disregarded federal law and the Petitioners’ religious convictions. The Petitioners were unceremoniously terminated from their employment and suffered financial, personal, and professional hardship. 

The Petitioners sued, filing a motion for a temporary restraining order (TRO) and preliminary injunction. The district court denied the TRO and granted the Defendants’ (Respondents) motions to dismiss the complaint. The Second Circuit later affirmed the dismissal. The lower courts justified the Respondents’ mandate by taking judicial notice of the “fact” that the COVID shots were “safe and effective” - treating this claim as not subject to reasonable dispute. 

America’s Frontline Doctors maintains the position that the COVID shots are not “vaccines” because they do not prevent infection or transmission. This makes them personal medical treatments ONLY.  Additionally, vast scientific research has proven these experimental mRNA injections to be neither safe nor effective. The CDC’s own Vaccine Adverse Event Reporting System (VAERS) has documented a horrific safety profile attributed to these shots with millions of adverse reactions. By “mandating” these dangerous medical treatments, the Respondents engaged in unconstitutional, illegal, and possible criminal activity in violation of numerous well-established laws and regulations. If left unchecked by the courts, these unlawful violations are likely to recur in the future. 

Further, the lower courts improperly took judicial notice of the false and hotly disputed “fact” that the experimental COVID-19 shots were “safe and effective.” Overwhelming evidence confirms that this “finding” is “subject to reasonable dispute,” which prohibits valid judicial notice. In doing so, the courts embraced the one-sided viewpoint of New York State public health authorities. This improper use of judicial notice threatens the integrity of the entire judicial system. In submitting our amici curiae brief, we are calling on the Supreme Court to correct the dangerous rulings of the lower courts and firmly reject New York’s tyrannical mandate.

AFLDS attorney David Dalia states, “Judicial notice is prohibited under the Federal Rules of Evidence for any fact that is ‘subject to reasonable dispute.’ So when the New York court takes judicial notice of the discredited and vigorously disputed ‘safe and effective’ narrative, in order to support a compulsory medical ‘mandate’ with nationwide implications, this dangerous ruling abusing judicial notice should be summarily reversed. For years, AFLDS has presented overwhelming evidence that these experimental mRNA injections are neither ‘safe,’ nor ‘effective.’ The body of data is clear. VAERS has recorded a shocking 38,615 American deaths attributed to these experimental mRNA gene therapies through April 25th, 2025 alone. This tells you everything you need to know.”

AFLDS Founder and President Dr. Simone Gold added, “Case by case, America’s Frontline Doctors and I have been fighting back against these totalitarian mandates. These cases are not about rectifying past grievances. They are about restoring the rule of law, reaffirming informed consent, and rejecting the medical tyranny that took root in the name of ‘health.’ We must ensure that all those harmed by these mandates are vindicated. These legal battles are the new frontline in the war for civil liberties. The fight for freedom is far from over, but we are gaining ground. Let history record that the reversal of COVID tyranny was not granted - it was won!”

Supporting these vital cases is critical to the mission of America’s Frontline Doctors. Please read our press releases for Brock v. City of Bellingham, Boyd v. Shriners, Sweeney v. UCHA, and Bridges v. The Methodist Hospital to learn more!

Stay tuned - We will keep you updated on the status of this case and our legal efforts to vindicate all those harmed by COVID mandates.

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