The new regulation removes religious exemptions as a basis for healthcare workers to decline the COVID-19 shots. All three individual plaintiffs are Christians, and object to the use of aborted fetal cell lines in the testing of the shots. The plaintiffs allege violations of the Free Exercise (of religion) clause of the First Amendment, as well as the rights to privacy and medical freedom protected by the First, Fourth, Fifth, and Fourteenth Amendments. Among other things, the plaintiffs assert that the state’s new mandate “violates the Free Exercise Clause by permitting a secular (medical) exemption on an individualized basis while categorically mandating the rejection of religious exemptions. … forcing the Plaintiffs and all healthcare workers in New York to choose between their religious beliefs and their jobs and careers.” The plaintiffs are asking the court to declare the new regulation unconstitutional and grant a permanent injunction preventing the state from enforcing it.