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  • Jonathan Lubin

We are challenging unconstitutional vaccine mandates in Illinois!

On September 23, 2021, a set of firefighter/EMS employees of the City of Naperville filed a lawsuit challenging unconstitutional vaccine mandates. The plaintiffs, represented by Jonathan Lubin, allege that the policy of forcing paramedics to vaccinate is unconstitutional in that it:

  1. Violates their substantive due process rights to make their own private medical decisions;

  2. Was signed by the governor without any authority under Illinois law; and

  3. Ignores scientific and medical realities.

Plaintiffs are a group of heroes who have risked their lives time and time again from the beginning of the pandemic through today. Now, the governor is trying to scapegoat these heroes, despite the consensus of the scientific community, and in violation of the law.

Halgren - Complaint FILED
Download PDF • 937KB

Halgren - Petition for TRO and PI FILED
Download PDF • 3.72MB

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JR McLinn
JR McLinn
Oct 04, 2021

Would the difference in infection from disease thus transmission prevention between the smallpox and covid vaccines be the agreement against Jacobson vs. Massachusetts police state ruling being applied to the current vaccine? Smallpox vaccine provides protection against infection thus prevention from transmission for 3-5 years. The current vaccines are now looking at booster shots at around 8 months following full vaccination.


Sep 28, 2021

How do other firefighter paramedics join this legal action? Many of us in Lake County are facing termination very soon if we don't take the shot and we need legal representation.

Chad Elliott
Chad Elliott
Oct 15, 2021
Replying to


Sep 24, 2021

Check out The Illinois Healthcare Right of Conscience Act (745 ILCS 70). It awards triple damages and a solid defense!

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