Last month, in We the Patriots USA v. Hochul, 17 F.4th 266 (2d Cir. 2021), the U.S. Court of Appeals for the Second Circuit reviewed two district court decisions that had reached different outcomes concerning the enforcement of New York state's vaccine mandate applicable to certain health care entities and personnel. In a unanimous per curium opinion, joined by Circuit Judge Susan Carney and Senior Circuit Judges John Walker and Robert Sack, the Second Circuit affirmed the District Court for the Eastern District of New York's refusal to block the mandate and reversed the District Court for the Northern District of New York, which had granted a preliminary injunction against the mandate. The Second Circuit held that the plaintiffs in each case were unlikely to succeed on the merits that the mandate contravenes the First Amendment's Free Exercise Clause, the Supremacy Clause, Title VII, or the Fourteenth Amendment right to privacy, medical freedom, and bodily autonomy. Id. at 281, 293-94.