No more excuses. Mandate the vaccine now.

See updates through September 16, 2021, at end of post.


I continue to wear the cloth masks my mother began making for me early in the COVID-19 pandemic, mostly only in situations where they’re required.

Being fully vaccinated, I know that my risk, even from the delta variant of COVID-19 is minimal.[1] The Center for Disease Control and Prevention’s advice to wear masks in areas of substantial or high transmission[2] is not really about vaccinated people. It is about unvaccinated people in the U.S., many of whom are actively refusing the vaccine,[3] even as case counts soar mostly among unvaccinated people;[4] even as hospitals face being overwhelmed; even as medical workers (often thanklessly, often even worse) put their lives on the line—because even full vaccination is not 100 percent effective—trying to save people’s lives;[5] even as people die.[6] Opposition to vaccines is largely ideological, particularly among supporters of Donald Trump.[7]

We are mostly (again, not entirely, because vaccines are not 100 percent effective[8]) performatively wearing masks because we cannot trust unvaccinated people to wear them,[9] neglecting, of course, a reality that those who refuse vaccines will also often refuse to wear masks, even where required.[10] The costs with the medical system, its overwhelming, the displacement of patients having to travel further for care when local hospitals are full, the risks to medical workers, are all real and substantial.[11] Finally, there is the possibility or likelihood that a new variant will arise, thanks again to the unvaccinated, that will pose a substantial risk even to the fully vaccinated.[12] There is a futility to all this that can really only be remedied through vaccination or death. So of course we are fed up.[13] It is far beyond unreasonable to expect us not to be.

The simple fact is that with an individualist claim to “freedom,” vaccine refusers entirely selfishly put the rest of us at risk even for our lives. There is no reason we should tolerate this. When our lives are at risk; when we have to wear masks because they refuse to; when we face the risk of a new, even more dangerous variant, their so-called “freedom” impinges upon, to say the very, very least, our freedom.

Vaccine refusers stand not on principle but on reckless disregard. With lives at risk, this can only be regarded as criminal. So, no more excuses. The vaccine must be mandatory.


Update, August 23, 2021: Not that this will change any minds—even Donald Trump got booed for recommending the vaccine at one of his own rallies[14]—but vaccine refusal is also costing real money: $2.3 billion in preventable costs over a two-month period, according to an estimate from the Peterson Foundation on Healthcare and Kaiser Family Foundation. Vaccinated people shouldn’t be bearing this cost but will, as the authors explain that “[t]he monetary cost of treating unvaccinated people for COVID-19 is borne not only by patients but also by society more broadly, including taxpayer-funded public programs and private insurance premiums paid by workers, businesses, and individual purchasers.”[15]

So, fine. Refuse the vaccine? Go to prison[16] and pay your share of that cost in restitution in addition to punitive fines.[17] Because this bullshit has to end.


Update, August 26, 2021: Hospitals are overflowing, largely due to the unvaccinated,[18] who continue to refuse the vaccine despite[19] full FDA approval.[20]

The sheer number of still-skeptical Americans — and their willingness to shift the goal posts on what might convince them — underscores that vaccination mandates are essential, said Robert Murphy, an infectious-disease physician and executive director of the Institute for Global Health at Northwestern University’s Feinberg School of Medicine.[21]

Spare me the bullshit. Throw these assholes in prison. Don’t release them until they’re dead or they’re fully vaccinated (yes, I mean two weeks after their final innoculation). And if they lose their jobs, so much the better; let them starve on the streets. They should be ineligible for social safety net benefits because those are expressions of a society where people fucking care about each other.


Update, September 2, 2021: NNancy Gibbs argues against denying medical care to those who have refused the COVID-19 vaccine, suggesting that the argument could be applied to any of a number of putatively “stupid” things people do. Of her examples, however, only smoking,[22] by way of second-hand smoke, really even begins to compare to the hazard the unvaccinated pose to others. My obesity certainly endangers myself, but it endangers no one else; COVID-19, on the other hand, is highly transmissible and specifically endangers the very people who would provide care.

Meanwhile, the problems of a medical care system stretched beyond its capacity increase,[23] with the attendant problem that, as Gibbs acknowledges, deserving, or at least more deserving, patients are having trouble accessing care.[24]


Update, September 3, 2021: Yesterday, I criticized Nancy Gibbs for what’s really a false analogy[25] in arguing that COVID-19 vaccine refusers should not be denied medical care when resources are tight.[26] I have failed, however, to make Uché Blackstock’s argument, and not because I didn’t want to.

Gibbs gains credibility by drawing on real world experience to highlight the dilemma,[27] but then fails to follow through with that experience in her conclusion. This is precisely where Blackstock shines.

Blackstock points to her experience having to take her infant to a pediatric intensive care unit (PICU). The child recovered and is now healthy. But imagine, she all but argues, if that PICU had not been available, taken up by a child whose parents had refused vaccination.[28]

I don’t argue for holding children, let alone infants, responsible for their parents’ sins. However, Gibbs’ argument fails precisely because it fails to take account of a reality, a reality that Blackstock fears,[29] that people will be denied medical care. This is not a question of whether we deny care, but rather, who will be denied care and why. In this situation, that why question directly implicates vaccine refusal.

(This update has been heavily edited to improve flow since it was initially published.)


Update, September 9, 2021:

President Biden announced sweeping new coronavirus vaccine mandates Thursday designed to affect tens of millions of Americans, ordering all businesses with more than 100 employees to require their workers to be immunized or face weekly testing.

Biden also said that he would require most health-care facilities that accept Medicare or Medicaid funding to vaccinate their employees, which the White House believes will cover 50,000 locations.

And the president signed an executive order compelling all federal employees to get vaccinated — without an option for those who prefer to be regularly tested instead — in an effort to create a model he hopes state governments will embrace. He is also ordering all staffers in Head Start programs, along with Defense Department and federally operated schools for Native Americans, to be vaccinated.[30]


Update, September 11, 2021: I don’t see how you argue against the necessity[31] for Joe Biden’s vaccine mandate.[32]

But the follow-on question is whether it’ll stand up in court. At the Los Angeles Times, Michael Hiltzik points to U.S. Supreme Court precedent, suggesting Biden is on ludicrously solid ground.[33] And indeed, he projects confidence.[34] The trouble, according to Hayley Fowler at the Sacramento Bee, is that it might not be so simple.[35] We do, after all, have an especially capricious Supreme Court.


Update, September 13, 2021: A Washington Post article on Joe Biden’s defiance of Republican governors’ lawsuit threats[36] covers little new ground in itself, but it does point to a month-old article in Lawfare in which the authors suspect “religious exemptions may well be constitutionally required under a future Supreme Court ruling.”[37]

In practice, this is likely to be a massive loophole. One thing Donald Trump did was to effectively unify[38] the authoritarian populist, social conservative, and paleoconservative tendencies of conservatism I identified in my dissertation,[39] erasing, as near as I can tell, the already-fuzzy distinctions between them. A great many pastors in evangelical Protestant churches have already offered faith in preference and opposition to medical mitigation measures. Capitalist libertarians who prize individualist ‘freedom’ even when it endangers others will likely think themselves clever—expect membership in the Universal Life Church and similar organizations to skyrocket—for exploiting this loophole. Traditionalist conservatives will likely find anti-vaccination bishops.

All pastors will have to do is to declare the vaccines un-Christian or blasphemous and their entire congregations will be exempt.

I do not know how many conservatives will avail themselves of such an exemption and, with ludicrously low response rates[40] and ongoing failures,[41] I distrust the methodology for determining this. But we can expect that a significant portion of Trump’s base to do so, possibly preventing the U.S. from vaccinating a sufficient proportion of the population to achieve ‘herd immunity.’


Update, September 16, 2021: In a previous update, I warned of a massive loophole if religious exemptions were allowed to vaccine mandates.[42] Well, here it is:

A pastor is encouraging people to donate to his Tulsa church so they can become an online member and get his signature on a religious exemption from coronavirus vaccine mandates. The pastor, Jackson Lahmeyer, is a 29-year-old small-business owner running in the Republican primary challenge to Sen. James Lankford in 2022.[43]


Update #2, September 16, 2021: ProPublica has a story on the difficulty people are having finding medical care because facilities in southern states (where vaccine resistance is high) are overwhelmed with—this needs to be emphasized—a largely preventable condition: COVID-19. People are dying.[44] The bullshit should have stopped long ago; it hasn’t.

  1. [1]Brianna Abbott, “CDC Says New Mask Guidelines Informed by Cape Cod Outbreak,” Wall Street Journal, July 30, 2021, https://www.wsj.com/articles/cdc-says-new-mask-mandate-informed-by-cape-cod-outbreak-11627664465; Yasmeen Abutaleb, Joel Achenbach, Dan Diamond, and Adam Taylor, “CDC urges vaccinated people in covid hot spots to resume wearing masks indoors,” Washington Post, July 27, 2021, https://www.washingtonpost.com/health/2021/07/27/cdc-masks-guidance-indoors/; Yasmeen Abutaleb, Carolyn Y. Johnson, and Joel Achenbach, “‘The war has changed’: Internal CDC document urges new messaging, warns delta infections likely more severe,” Washington Post, July 29, 2021, https://www.washingtonpost.com/health/2021/07/29/cdc-mask-guidance/; Anne Flaherty and Arielle Mitropoulos, “CDC mask decision followed stunning findings from Cape Cod beach outbreak,” ABC News, July 29, 2021, https://abcnews.go.com/Politics/cdc-mask-decision-stunning-findings-cape-cod-beach/story?id=79148102; Carolyn Y. Johnson, Yasmeen Abutaleb, and Joel Achenbach, “CDC study shows three-fourths of people infected in Massachusetts coronavirus outbreak were vaccinated but few required hospitalization,” Washington Post, July 30, 2021, https://www.washingtonpost.com/health/2021/07/30/provincetown-covid-outbreak-vaccinated/; David Leonhardt to Morning list, “A confusing message,” New York Times, July 28, 2021, https://messaging-custom-newsletters.nytimes.com/template/oakv2?abVariantId=0&campaign_id=9&emc=edit_nn_20210728&instance_id=36411&nl=the-morning&productCode=NN&regi_id=97793637&segment_id=64604&te=1&uri=nyt%3A%2F%2Fnewsletter%2F12f5196d-ad87-5d92-8259-21654fdb0c86&user_id=087ade925ce15f15a24824418c4789ce; Justin Miller and David Wallace-Wells, “What If Vaccines Don’t Really Stop the Virus From Spreading?” New York, July 28, 2021, https://nymag.com/intelligencer/2021/07/covid-vaccines-may-not-totally-stop-delta-from-spreading.html; Luke Money and Faith E. Pinho, “Wary of ‘breakthrough’ infections, some vaccinated people eye another shot. Is it needed?” Los Angeles Times, August 7, 2021, https://www.latimes.com/california/story/2021-08-07/with-breakthrough-infections-some-vaccinated-people-look-for-more-protection-are-boosters-needed; Aparna Nathan, “Delta-plus and lambda variants don’t yet warrant panic for vaccinated people, Philly experts say,” Philadelphia Inquirer, August 4, 2021, https://www.inquirer.com/health/coronavirus/delta-plus-lamda-philadelphia-vaccinated-what-to-know-20210804.html; Sabrina Siddiqui and Tarini Parti, “CDC Urges Vaccinated People to Resume Wearing Masks Indoors in Some Areas,” Wall Street Journal, July 27, 2021, https://www.wsj.com/articles/cdc-to-urge-vaccinated-people-to-resume-wearing-masks-in-public-indoor-spaces-11627399286; Brian Stelter and Oliver Darcy, “White House blasts Covid coverage,” CNN, July 30, 2021, https://view.newsletters.cnn.com/messages/1627696990899989e7b7635dc/raw
  2. [2]Sabrina Siddiqui and Tarini Parti, “CDC Urges Vaccinated People to Resume Wearing Masks Indoors in Some Areas,” Wall Street Journal, July 27, 2021, https://www.wsj.com/articles/cdc-to-urge-vaccinated-people-to-resume-wearing-masks-in-public-indoor-spaces-11627399286
  3. [3]Democracy Now! “‘We Can’t Trust the Unvaccinated’: Dr. Leana Wen on Vaccine Mandates & How to Stop the Delta Variant,” July 29, 2021, https://www.democracynow.org/2021/7/29/covid_19_delta_variant_leana_wen; Leana S. Wen, “The CDC needs to make clear: The problem is the unvaccinated,” Washington Post, July 29, 2021, https://www.washingtonpost.com/opinions/2021/07/29/leana-wen-cdc-mask-guidance-unvaccinated-problem/
  4. [4]Brianna Abbott, “Delta Variant Accounts for 83% of Known U.S. Covid-19 Cases,” Wall Street Journal, July 20, 2021, https://www.wsj.com/articles/delta-variant-accounts-for-83-of-known-covid-19-cases-11626807019; Associated Press, “U.S. now averaging 100,000 new coronavirus infections a day,” Los Angeles Times, August 6, 2021, https://www.latimes.com/world-nation/story/2021-08-06/u-s-now-averaging-100-000-new-coronavirus-infections-a-day; Joseph Ax and Nathan Layne, “Delta variant surges across U.S. South; political leaders clamp down again,” Reuters, August 3, 2021, copy in possession of author; Chandelis Duster, “Fauci: ‘We’re going in the wrong direction’ on Covid-19 cases,” CNN, July 25, 2021, https://edition.cnn.com/2021/07/25/politics/anthony-fauci-covid-19-unvaccinated-cnntv/index.html; Aya Elamroussi, “‘This is starting to look really ominous in the South,’ expert says, as US is among nations with highest rate of new Covid-19 cases,” CNN, August 14, 2021, https://www.cnn.com/2021/08/14/health/us-coronavirus-saturday/index.html; Melanie Evans and Julie Wernau, “Unvaccinated Americans Are Behind Rising Covid-19 Hospitalizations,” Wall Street Journal, July 18, 2021, https://www.wsj.com/articles/unvaccinated-covid-19-hospitalizations-11626528110; Ed Pilkington and Lauren Aratani, “US seeing ‘pandemic of the unvaccinated’ as cases rise in every state,” Guardian, July 16, 2021, https://www.theguardian.com/world/2021/jul/16/covid-19-us-delta-variant-unvaccinated; Brad Reed, “Georgia county shuts down all of its schools for two weeks after mass COVID-19 outbreak,” Raw Story, August 13, 2021, https://www.rawstory.com/georgia-schools/; Greg Sargent, “A vile new Trump-GOP claim about vaccines suggests trouble ahead,” Washington Post, July 19, 2021, https://www.washingtonpost.com/opinions/2021/07/19/vile-new-trump-gop-claim-about-vaccines-suggests-trouble-ahead/
  5. [5]Brianna Abbott, “Covid-19 Rise, Vaccine Hesitancy Frustrate Doctors in Hospitals Saturated by the Delta Variant,” Wall Street Journal, August 12, 2021, https://www.wsj.com/articles/covid-19-rise-vaccine-hesitancy-frustrate-doctors-in-hospitals-saturated-by-the-delta-variant-11628760602; Rhys Blakely, “Double Covid vaccine doesn’t stop symptoms for half of Delta cases,” Times, August 19, 2021, https://www.thetimes.co.uk/article/double-covid-vaccine-symptoms-delta-variant-cases-8jfxkzp03; Justine Coleman, “Pfizer vaccine effectiveness drops to 84 percent after six months: data,” Hill, July 28, 2021, https://thehill.com/policy/healthcare/565282-pfizer-biontech-vaccine-effectiveness-drops-to-84-percent-after-six-months; Jacqueline Howard, “Pfizer data suggest third dose of Covid-19 vaccine ‘strongly’ boosts protection against Delta variant,” CNN, July 28, 2021, https://www.cnn.com/2021/07/28/health/pfizer-third-dose-data-bn/index.html; Carolyn Y. Johnson, Yasmeen Abutaleb, and Joel Achenbach, “CDC study shows three-fourths of people infected in Massachusetts coronavirus outbreak were vaccinated but few required hospitalization,” Washington Post, July 30, 2021, https://www.washingtonpost.com/health/2021/07/30/provincetown-covid-outbreak-vaccinated/; Oliver Laughland and Jessica Glenza, “Inside a Tennessee hospital grappling with Delta and vaccine hesitancy,” Guardian, July 24, 2021, https://www.theguardian.com/us-news/2021/jul/24/tennessee-coronavirus-covid-delta-variant-cases-vaccines; Natasha Lindstrom, “Out-of-state covid hot spots ‘desperate’ to transfer patients to Western Pa. hospitals,” Pittsburgh Tribune-Review, August 12, 2021, https://triblive.com/news/health-now/out-of-state-covid-hot-spots-desperate-to-transfer-patients-to-western-pa-hospitals/; Justin Miller and David Wallace-Wells, “What If Vaccines Don’t Really Stop the Virus From Spreading?” New York, July 28, 2021, https://nymag.com/intelligencer/2021/07/covid-vaccines-may-not-totally-stop-delta-from-spreading.html; Paige Williams, “Mississippi’s Hospital System Is Rapidly Approaching Statewide Failure,” New Yorker, August 17, 2021, https://www.newyorker.com/news/us-journal/mississippis-hospital-system-is-rapidly-approaching-statewide-failure
  6. [6]Edward Helmore, “Rightwing radio host and anti-vaxxer dies of Covid,” Guardian, August 8, 2021, https://www.theguardian.com/us-news/2021/aug/08/rightwing-radio-host-dick-farrel-anti-vaxxer-dies-covid; Rob Stein and Selena Simmons-Duffin, “The Delta Variant Will Drive A Steep Rise In U.S. COVID Deaths, A New Model Shows,” National Public Radio, July 22, 2021, https://www.npr.org/sections/health-shots/2021/07/22/1019475669/delta-variant-will-drive-a-steep-rise-in-covid-deaths-model-shows
  7. [7]Aaron Blake, “The GOP is losing the argument on coronavirus mandates,” Washington Post, August 19, 2021, https://www.washingtonpost.com/politics/2021/08/18/gop-is-losing-pr-battle-coronavirus-mandates/; Dan Diamond, Hannah Knowles, and Tyler Pager, “Vaccine hesitancy morphs into hostility, as opposition to shots hardens,” Washington Post, July 15, 2021, https://www.washingtonpost.com/politics/covid-vaccines-biden-trump/2021/07/15/adaf6c7e-e4bd-11eb-a41e-c8442c213fa8_story.html; Michael M. Grynbaum, Tiffany Hsu, and Zolan Kanno-Youngs, “On Fox News, Vaccination Pleas Intensify, but Skepticism Persists,” New York Times, July 20, 2021, https://www.nytimes.com/2021/07/20/business/media/fox-news-covid-vaccines.html; Jenny Jarvie, Richard Read, and Molly Hennessy-Fiske, “With Delta surging, America is dangerously divided over vaccines,” Los Angeles Times, August 5, 2021, https://www.latimes.com/world-nation/story/2021-08-05/united-states-covid-vaccines-divisions; Ed Kilgore, “The Willfully Unvaccinated Are the Newest Republican Martyrs,” New York, July 13, 2021, https://nymag.com/intelligencer/2021/07/the-willfully-unvaccinated-are-the-newest-republican-martyrs.html; Hannah Knowles, “DeSantis sells ‘Don’t Fauci My Florida’ merch as new coronavirus cases near highest in nation,” Washington Post, July 14, 2021, https://www.washingtonpost.com/politics/2021/07/13/desantis-fauci-florida/; Hannah Knowles, “A Texas GOP official’s covid-19 death went viral. Then came calls for vaccination — and bitter divides,” Washington Post, August 21, 2021, https://www.washingtonpost.com/health/2021/08/21/scott-apley-covid-death-vaccine/; Jeremy Kohler, “GOP Legislators in Missouri Oppose Vaccine Efforts as State Becomes COVID Hotspot,” Pro Publica, July 21, 2021, https://www.propublica.org/article/missouri-legislators-oppose-vaccine-efforts-as-state-becomes-covid-hotspot; Summer Lin, “Got your COVID vaccine? Stay out, says California restaurateur decrying ‘stupidity,’” Sacramento Bee, July 26, 2021, https://www.sacbee.com/news/coronavirus/article253039643.html; David Litt, “Republicans used to laud ‘personal responsibility’. Not with Covid,” Guardian, July 30, 2021, https://www.theguardian.com/commentisfree/2021/jul/30/republicans-used-to-laud-personal-responsibility-not-with-covid; Jaclyn Peiser, “Evangelical pastor demands churchgoers ditch their masks: ‘Don’t believe this delta variant nonsense,’” Washington Post, July 27, 2021, https://www.washingtonpost.com/nation/2021/07/27/tennessee-pastor-greg-locke-masks/; Bryan Pietsch, “Twitter suspends Rep. Marjorie Taylor Greene for spreading covid-19 misinformation,” Washington Post, July 20, 2021, https://www.washingtonpost.com/politics/2021/07/20/marjorie-taylor-green-twitter-suspended-covid/; Hannah Wiley, “‘No masks. No vaccines.’ Battle is brewing over coronavirus immunizations in California,” Sacramento Bee, June 26, 2020, https://www.sacbee.com/news/politics-government/capitol-alert/article243381501.html
  8. [8]Rhys Blakely, “Double Covid vaccine doesn’t stop symptoms for half of Delta cases,” Times, August 19, 2021, https://www.thetimes.co.uk/article/double-covid-vaccine-symptoms-delta-variant-cases-8jfxkzp03; Justine Coleman, “Pfizer vaccine effectiveness drops to 84 percent after six months: data,” Hill, July 28, 2021, https://thehill.com/policy/healthcare/565282-pfizer-biontech-vaccine-effectiveness-drops-to-84-percent-after-six-months; Jacqueline Howard, “Pfizer data suggest third dose of Covid-19 vaccine ‘strongly’ boosts protection against Delta variant,” CNN, July 28, 2021, https://www.cnn.com/2021/07/28/health/pfizer-third-dose-data-bn/index.html; Carolyn Y. Johnson, Yasmeen Abutaleb, and Joel Achenbach, “CDC study shows three-fourths of people infected in Massachusetts coronavirus outbreak were vaccinated but few required hospitalization,” Washington Post, July 30, 2021, https://www.washingtonpost.com/health/2021/07/30/provincetown-covid-outbreak-vaccinated/; Justin Miller and David Wallace-Wells, “What If Vaccines Don’t Really Stop the Virus From Spreading?” New York, July 28, 2021, https://nymag.com/intelligencer/2021/07/covid-vaccines-may-not-totally-stop-delta-from-spreading.html
  9. [9]Democracy Now! “‘We Can’t Trust the Unvaccinated’: Dr. Leana Wen on Vaccine Mandates & How to Stop the Delta Variant,” July 29, 2021, https://www.democracynow.org/2021/7/29/covid_19_delta_variant_leana_wen; Leana S. Wen, “The CDC needs to make clear: The problem is the unvaccinated,” Washington Post, July 29, 2021, https://www.washingtonpost.com/opinions/2021/07/29/leana-wen-cdc-mask-guidance-unvaccinated-problem/
  10. [10]Hannah Wiley, “‘No masks. No vaccines.’ Battle is brewing over coronavirus immunizations in California,” Sacramento Bee, June 26, 2020, https://www.sacbee.com/news/politics-government/capitol-alert/article243381501.html
  11. [11]Brianna Abbott, “Covid-19 Rise, Vaccine Hesitancy Frustrate Doctors in Hospitals Saturated by the Delta Variant,” Wall Street Journal, August 12, 2021, https://www.wsj.com/articles/covid-19-rise-vaccine-hesitancy-frustrate-doctors-in-hospitals-saturated-by-the-delta-variant-11628760602; Rhys Blakely, “Double Covid vaccine doesn’t stop symptoms for half of Delta cases,” Times, August 19, 2021, https://www.thetimes.co.uk/article/double-covid-vaccine-symptoms-delta-variant-cases-8jfxkzp03; Justine Coleman, “Pfizer vaccine effectiveness drops to 84 percent after six months: data,” Hill, July 28, 2021, https://thehill.com/policy/healthcare/565282-pfizer-biontech-vaccine-effectiveness-drops-to-84-percent-after-six-months; Jacqueline Howard, “Pfizer data suggest third dose of Covid-19 vaccine ‘strongly’ boosts protection against Delta variant,” CNN, July 28, 2021, https://www.cnn.com/2021/07/28/health/pfizer-third-dose-data-bn/index.html; Carolyn Y. Johnson, Yasmeen Abutaleb, and Joel Achenbach, “CDC study shows three-fourths of people infected in Massachusetts coronavirus outbreak were vaccinated but few required hospitalization,” Washington Post, July 30, 2021, https://www.washingtonpost.com/health/2021/07/30/provincetown-covid-outbreak-vaccinated/; Oliver Laughland and Jessica Glenza, “Inside a Tennessee hospital grappling with Delta and vaccine hesitancy,” Guardian, July 24, 2021, https://www.theguardian.com/us-news/2021/jul/24/tennessee-coronavirus-covid-delta-variant-cases-vaccines; Natasha Lindstrom, “Out-of-state covid hot spots ‘desperate’ to transfer patients to Western Pa. hospitals,” Pittsburgh Tribune-Review, August 12, 2021, https://triblive.com/news/health-now/out-of-state-covid-hot-spots-desperate-to-transfer-patients-to-western-pa-hospitals/; Justin Miller and David Wallace-Wells, “What If Vaccines Don’t Really Stop the Virus From Spreading?” New York, July 28, 2021, https://nymag.com/intelligencer/2021/07/covid-vaccines-may-not-totally-stop-delta-from-spreading.html; Paige Williams, “Mississippi’s Hospital System Is Rapidly Approaching Statewide Failure,” New Yorker, August 17, 2021, https://www.newyorker.com/news/us-journal/mississippis-hospital-system-is-rapidly-approaching-statewide-failure
  12. [12]Maggie Fox, “Unvaccinated people are ‘variant factories,’ infectious diseases expert says,” CNN, July 3, 2021, https://www.cnn.com/2021/07/03/health/unvaccinated-variant-factories/index.html
  13. [13]Timothy Bella, “An Alabama doctor watched patients reject the coronavirus vaccine. Now he’s refusing to treat them,” Washington Post, August 18, 2021, https://www.washingtonpost.com/health/2021/08/18/alabama-doctor-unvaccinated-patients-valentine/; Dan Diamond and Tyler Pager, “‘Patience has worn thin’: Frustration mounts over vaccine holdouts,” Washington Post, July 23, 2021, https://www.washingtonpost.com/health/2021/07/23/anger-targets-vaccine-holdouts-delta-surge/; David Frum, “Vaccinated America Has Had Enough,” Atlantic, July 23, 2021, https://www.theatlantic.com/ideas/archive/2021/07/vaccinated-america-breaking-point-anti-vaxxers/619539/; Juliette Kayyem, “Unvaccinated People Need to Bear the Burden,” Atlantic, August 3, 2021, https://www.theatlantic.com/ideas/archive/2021/08/unvaccinated-flight-vaccine-tsa-mandate/619643/; Ruth Marcus, “Require the vaccine. It’s time to stop coddling the reckless,” Washington Post, July 30, 2021, https://www.washingtonpost.com/opinions/2021/07/30/require-vaccine-its-time-stop-coddling-reckless/; Justine McDaniel, Allison Steele, and Erin McCarthy, “‘Enough is enough’: Gov. Murphy’s outburst was the latest sign of rising anger over pandemic divide,” Philadelphia Inquirer, August 5, 2021, https://www.inquirer.com/news/murphy-vaccine-covid-protest-nj-vaccinated-20210805.html; Jennifer Rubin, “Americans have had it with vaccine refusers and anti-mandate politicians,” Washington Post, August 4, 2021, https://www.washingtonpost.com/opinions/2021/08/04/americans-have-had-it-with-vaccine-refusers-anti-mandate-pols/; Helen Ubiñas, “Stop begging the COVID bullies. We can’t ‘nice’ people into doing the right thing,” Philadelphia Inquirer, August 13, 2021, https://www.inquirer.com/opinion/covid-masks-mandates-vaccines-philadelphia-mayor-kenney-helen-ubinas-20210813.html; Paul Waldman, “I’m tired of being nice to vaccine refusers,” Washington Post, July 27, 2021, https://www.washingtonpost.com/opinions/2021/07/27/im-tired-being-nice-vaccine-refusers/
  14. [14]Guardian, “Trump booed after telling supporters to get Covid vaccine,” August 22, 2021, https://www.theguardian.com/us-news/2021/aug/22/donald-trump-rally-alabama-covid-vaccine
  15. [15]Krutika Amin and Cynthia Cox, “Unvaccinated COVID-19 hospitalizations cost the U.S. health system billions of dollars,” Peterson Foundation on Healthcare and Kaiser Family Foundation, August 20, 2021, https://www.healthsystemtracker.org/brief/unvaccinated-covid-patients-cost-the-u-s-health-system-billions-of-dollars/
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  17. [17]Restitution and punitive fines cannot be discharged through bankruptcy. Nannette Dean, “Will Bankruptcy Court Clear Court Fines?” Nolo, 2021, https://www.nolo.com/legal-encyclopedia/will-bankruptcy-court-clear-court-fines.html
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