Adams v. United States of America

On March 16, 2023, the United States Court of Federal Claims issued a ruling in Adams v. United States of America, a class action lawsuit brought by active-duty and former members of the U.S. Air Force and Space Force. The plaintiffs, led by Justin Adams, alleged that the military’s denial of their requests for religious accommodation from the COVID-19 vaccination mandate violated the Religious Freedom Restoration Act (RFRA) and the First Amendment. They claimed constructive discharge and sought back pay and reinstatement. The government moved to dismiss for lack of jurisdiction and failure to state a claim. The court denied the motion in substantial part, allowing the core religious liberty claims to proceed. The case became a leading example of the judiciary’s role in reviewing military policies that intersect with fundamental civil liberties during the pandemic era.

The court denied the government's motion to dismiss, holding that the plaintiffs had plausibly alleged violations of RFRA and that the court had jurisdiction over their claims for back pay under the Tucker Act. The case proceeded to discovery.

Whether the denial of religious exemptions to the COVID-19 vaccine mandate violated the Religious Freedom Restoration Act and the Free Exercise Clause, and whether the court possessed jurisdiction to award monetary relief for constructive discharge.

The decision, issued shortly after the Department of Defense rescinded the COVID-19 vaccine mandate in January 2023, affirmed that service members could pursue back pay and corrective action for past religious discrimination. It energized ongoing religious liberty litigation and highlighted the lasting legal consequences of pandemic-era military policies.