On June 30, 2015, the Governor signed into law Senate Bill No. 277, which takes effect on July 1, 2016.  [Senate Bill No. B 277: “An act to amend Sections 120325, 120335, 120370, and 120375 of, to add Section 120338 to, and to repeal Section 120365 of the Health and Safety Code, relating to public health.”]
          SB 277 removes the “personal beliefs” exemption as a basis for parents       to opt-out of state mandated “immunization” requirements for schoolchildren.  Plaintiffs oppose this tyrannical bill because it wrongfully places the interests of the national vaccine market above the interests of California children; and sadly, this is a symptom of a larger sickness that debilitates the nation.  America stands alone; we are the only nation on Earth in which healthcare is dispensed first and foremost to create shareholder value, and only secondarily for health-related reasons, and even then, with little or no regard for patients’ rights as individuals. 
          SB 277 provides that students will be admitted to school only upon proof   of “immunization” against a minimum of ten (10) different childhood diseases.  The State hopes to reach a goal of “total immunization,” (is such goal possible?), by injecting into children’s bodies whichever chemicals or ingredients the State,    in its sole discretion, and ineffable wisdom, deems necessary and appropriate.
          In furtherance of this stated goal -- “total immunization” -- the State openly and notoriously declares it will take the extreme and outrageous step of denying California children their fundamental right to go to school -- regardless of parents’ “personal beliefs,” including their sincerely held philosophic, conscientious, and religious objections to State-mandated immunization.  Plaintiffs seek to strike down SB 277 and restore the “personal beliefs” exemption to all State-mandated vaccine programs for California schoolchildren.  Plaintiffs seek a preliminary and permanent injunction forever halting SB 277.    
          If SB 277 takes effect, California will be left with a decidedly “segregated” school system -- vaxxed and unvaxxed -- where many children will suffer invidious discrimination based on “medical status” (a protected class under California law).  Under a Brown vs. Board of Education analysis, such a bifurcated school system -- vaxxed and unvaxxed -- reeks of “separate-but-equal,” and thus, cannot be allowed to stand.  Under California law, segregation based on “medical status” is every bit as odious as segregation based on “race,” “creed” or “color.”  [See Brown vs. Board of Education of Topeka, (1954) 347 U.S. 483]
          Plaintiffs sue to enforce their children’s constitutional right to an education regardless of “immunization status” (i.e., “medical status”), and also to enforce a parent’s rights to exercise “personal beliefs” in opposition to State-mandated immunization requirements by asserting their own various philosophic objections, (“Herd immunity is fraud!”), conscientious objections, (“My family is Vegan!”), and religious objections, (“Aborted fetal cells?--No way!”).
          SB 277 violates the children’s fundamental right to attend school, (Calif. Const. Art. 9, Sec. 5), and it also violates the parents’ fundamental right to freely exercise their “personal beliefs” (Free Exercise Clause, First Amendment). 
          Plaintiffs cannot understate the historical significance and sheer weight of the First Amendment; the right to “freely exercise religion” forms the very cornerstone of democracy.  Plaintiffs believe The Founders placed “freedom of religion” in the First Amendment because it is the most fundamental of all rights, quite literally, the number one most cherished right of free-thinking people.
          The Free Exercise Clause protects the individual in his or her free expression of “personal beliefs” -- especially those beliefs that run contrary to the State. The First Amendment allows individuals to freely exercise “personal beliefs” and freely make their own joyful noise without leave or hindrance from the State.  This lawsuit recognizes no public health crisis; rather, this lawsuit champions  civil liberties, personal freedoms, and restores the rights of the individual. 
          Plaintiffs steadfastly refuse to surrender their constitutional right to exercise “personal beliefs” -- i.e., their sincerely held philosophic, conscientious, and religious objections to State-mandated immunization; furthermore, Plaintiffs refuse to surrender their children’s constitutional right to go to school.

          Plaintiffs should not be required to surrender one constitutional right to get to another.  Plaintiffs should not be placed in the untenable position of having to choose between the right to educate their children, (Calif. Const. Art. 9, Sec. 5), and the right to freely exercise their “personal beliefs” in opposition to State-mandated immunization, (Free Exercise Clause, First Amendment).  
          Plaintiffs seek a court order striking down SB 277 as unconstitutional. Plaintiffs seek preliminary and permanent injunctive relief in order to preserve the status quo and to halt enforcement of SB 277.  [California Health & Safety Code §§120325 - 20380].
          Most significantly, SB 277 implicates “fundamental rights,” chiefly, the children’s fundamental right to go to school, (Calif. Constitution), and the parents’ fundamental right to freely exercise their “personal beliefs,” (First Amendment).  The “right to go to school” and the “right to freely exercise personal beliefs” are constitutional rights, and thus, “fundamental” rights. 
Where, as here, “fundamental rights” are at stake, courts must employ a heightened level of judicial review, “strict scrutiny.”  Under a “strict scrutiny” analysis, this Court must strike down SB 277 because, when all’s said, the State’s interest in educating children is necessarily more compelling than its interest in vaccinating them.
          Here, because Plaintiffs allege violations of fundamental rights, the burden of proof “shifts” to the State to demonstrate a “compelling governmental interest” in SB 277, and further, the State has the burden to demonstrate that Sacramento lawmakers “narrowly tailored” SB 277 to achieve only that specific governmental interest, with no “less-restrictive means” available.
          The stated goal of SB 277 is the “total immunization” of all California schoolchildren. [See Calif. H&S Code §120325(a)]  However, this Orwellian goal of “total immunization,” is factually impossible to achieve, and thus, the State,     as a matter of law, can never meet its legal burden, and Plaintiffs thus prevail. 
          Why is the goal of “total immunization” impossible?  As a threshold matter, and this is most significant, vaccine makers do not guarantee any “immunization.”  And, because vaccine makers do not guarantee any “immunization,” it is factually impossible for vaccinated children to guarantee “immunization” to the State, and, ipso facto, it’s impossible to achieve the stated goal of “total immunization.”
          Assuming vaccine makers file motions to intervene in the instant litigation, Plaintiffs are confident that vaccine makers will corroborate the fact that their vaccines come with absolutely, positively zero guarantees, warranties, or promises, express or implied, of any kind whatsoever.  None!
          Bending to the will of the national vaccine market, the State-mandated “immunization” program is built on a faulty premise; the State, (wittingly or unwittingly?), labors under the false premise that vaccination always results in “immunization,” but Plaintiffs reemphasize -- this is flatly false.    
           Plaintiffs argue there can be no “compelling governmental interest” in        the stated goal of “total immunization” simply because such goal is impossible;     and the impossibility factor lay in the irrefutable premise that vaccines come with no guarantee of “immunization.” 
          Forgetting for a moment what may be dubious motives underlying this goal of “total immunization,” Plaintiffs point out the availability of “less-restrictive means” of achieving such a goal (if indeed it be a worthwhile goal); for example, where parents are concerned about “immunization,” such parents are always free  to “immunize,” if they so choose, or where parents are concerned about disease prevention generally, they are free to seek advice or treatment consistent with their own “personal beliefs” (philosophic, conscientious, and religious).
          And, where the State has legitimate concern about disease prevention, (unrelated to concerns for the national vaccine market), the State may undertake disease-prevention awareness; but ultimately, all decisions regarding whether to “immunize” must be made by the parents, not the State.
          It is worth noting that SB 277 is conspicuously silent as to the words “vaccine” or “vaccination.”  Remarkable as it sounds, neither the words “vaccine” nor “vaccination” ever appear at SB 277; and Plaintiffs were surprised when they learned this!  Most notably, SB 277 uses only the term “immunization,” (but never the term “vaccination”).  And this is quite significant because, of course, there is    a world of difference between “vaccination” and “immunization.”
           The term “immunization” is a conclusion that a disease-fighting shield is     in effect; whereas, by contrast, the term “vaccination” refers to a one-time medical event that (ostensibly) leads to “immunization.”  The language of Sacramento lawmakers is clear and unambiguous -- no vaccines required!  SB 277 requires only “immunization,” and Plaintiffs’ children are already naturally “immunized.”   
          The State’s interest in achieving “total immunization” must necessarily    take a backseat to the California Constitution, which guarantees the fundamental right to free, public education. [Calif. Const., Art. 9, Sec. 5]  The California Supreme Court stands firmly on this fundamental right, stating: “[S]ociety has a compelling interest in affording children an opportunity to attend school.”  [Serrano v. Priest, (1971) 5 Cal. 3d 584, 606, 487 P.2d 1241, 1257].
          The U.S. Supreme Court recognizes the right to refuse unwanted medical interventions.  [Cruzan v. Director Missouri Dept. Health, (1990) 497 U.S. 261, 278]   And, when it comes to the children’s best interests, it is the parents, not     the State, who shall have the right to make healthcare decisions.  A child is not a “mere creature of the State.” [Parham v. J.R., (1979) 422 U.S. 584]  Plaintiffs contend that SB 277 wrongfully removes the parents as decision-makers and wrongfully delegates decision-making to the State.
          The U.S. Supreme Court also recognizes the fundamental interest of parents, in contrast with that of the State, to guide the religious education of their children.  Western history and culture “reflect a strong tradition of parental concern for the nurture and upbringing of their children which the State should not ignore.”  [Wisconsin vs. Yoder,(1972) 406 U.S. 205, 92 S. Ct. 1526, 32 L. Ed. 2d 15]
          Plaintiffs believes the Court may take judicial notice of the fact that vaccines maim and kill children.  The horror of this reality is mind-numbing.  And, in too many instances, vaccines turn out to be more injurious and more deadly than the predicate diseases for which the vaccines were administered in the first place.    For example, over the past ten years, the number of schoolchildren who have    died from the MMR vaccine far outpaces the number of measle deaths (if any).    In fact, the MMR vaccine has a disastrous “success” rate of killing approximately one American child, every month, for the last ten years; sadly, when it comes to measles “immunization,” it’s hard to tell the poison from the cure.
          Back in 1986, seeking to stabilize the national vaccine market, Congress passed the National Childhood Vaccine Injury Act, [42 U.S.C. §§ 300aa-1 to 300aa-34; ("The Act")], and since its creation, the national Vaccine Injury Compensation Program, ("VICP"), has paid-out more than three billion dollars      (taxpayer money) on vaccine injury and wrongful death claims.
          The Act protects the national vaccine market by forbidding would-be plaintiffs from suing vaccine makers at the county courthouse; the Act instead funnels plaintiffs into an arbitration quagmire -- which has no legal mechanism to subpoena industry documents that might tend to prove things like vaccine  design defects or manufacturing defects.  The Act further protects vaccine makers by relieving them of having to pay monetary compensation to vaccine victims;   the Act instead saddles taxpayers with the burden of funding injury compensation.  The purpose of the Act is to stabilize the national vaccine market by allowing vaccine makers to dodge jury trials and class action lawsuits.
          The Act bestows upon the national vaccine market what amounts to almost total immunity from liability -- and Congress generously heaped this special dispensation on vaccine makers because vaccines are “unavoidably unsafe.”    Even if properly designed and manufactured in strict accordance with FDA rules, vaccines nevertheless remain “unavoidably unsafe.”  [Bruesewitz v. Wyeth LLC, (2011) 562 U.S. 223, 131 S. Ct. 1068, 1089, 179 L. Ed. 2d 1]
          “But for” the Act, jury trials and class action lawsuits would destabilize     the national vaccine market -- then overwhelm and capsize it -- because vaccines are “unavoidably unsafe.”  Without the Act’s protection, vaccine makers would lose every lawsuit and be driven out-of-business by personal injury lawyers.
Tragically, instead of removing “unavoidably unsafe” products from the marketplace, Congress instead removed the specter of liability, and this in turn removed all incentive for vaccine safety.  So now, when vaccines kill or maim, vaccine makers pay no monetary damages to the victims -- because Congress foisted that duty upon the American taxpayer -- who must “bail out” vaccine makers for their negligent design and manufacturing defects.    
          Again, even if a vaccine is free of design defect and manufacturing defect,   it nevertheless remains “unavoidably unsafe” as a matter of law.  When rendering final judgement, Plaintiffs pray the court will acknowledge this irrefutable premise, i.e., that all vaccines are “unavoidably unsafe.”

          The popular media pretends that vaccines are “safe and effective,” but this  is a blatant falsehood; as a matter of law, all vaccines are “unavoidably unsafe,” and for this reason alone, parents are wise to opt-out of mandatory immunization because sometimes, indeed, all too often, vaccines go wrong.
          Perhaps most disturbing of all, when vaccines go wrong, vaccine makers   are utterly incapable of explaining “why.”  But this comes as no surprise because vaccine makers are just as incapable of explaining “how” their vaccines (supposedly) bring about immunization.     
          Plaintiffs view all vaccine makers with mistrust and suspicion because:      (i) vaccine makers do not guarantee “immunization;” (ii) persons injured by vaccines cannot sue vaccine makers at the county courthouse; (iii) taxpayers must subsidize the vaccine maker’s design defects, manufacturing defects, personal injury claims and wrongful death claims; and (iv) all vaccines are deemed “unavoidably unsafe” due to the ever-present risk of death or great bodily injury; and (v) vaccine makers cannot explain how their products work, nor why they fail.
          The United States Court of Appeals recognizes that medical science is a “field bereft of complete and direct proof of how vaccines affect the human body.” [Althen v. Sec’y of Health & Human Servs., 418 F.3d 1274 (Fed. Cir. 2005)]
          Science cannot explain “why” vaccines kill, nor can science predict “who” will next suffer vaccine injuries or “when.”  Under a simple cost-benefit analysis, the “costs” associated with vaccines clearly outweigh any “benefit” -- because   vaccines come with no immunization guarantee and instead carry the very palpable risk of death.        
          SB 277 violates the constitutional rights of Plaintiffs and their children.  Plaintiffs request preliminary and permanent injunctive relief that declares SB 277 unconstitutional, and further, restrains The State of California from enforcing SB 277 and its “immunization” mandates. 
          Epilogue:  Freedom means nothing if you can't keep the government out of your body.
Dated:  April 22, 2016                      Law Offices of T. Matthew Phillips

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Sarah Lucas

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Locally, nationally and internationally, REVOLT.REVOKE.RESTORE is a vocal advocate for parental and religious rights. We seek to overturn this unjust law created by overreaching government, and we're committed to restoring equal access to education for all children in California. . 

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​​REVOLT.REVOKE.RESTORE invites you to help us passionately advocate for the restoration of personal belief and religious vaccine exemptions in California. A group of committed parents have joined to crowd fund to bring back vaccine exemptions in the great state of California. These are basic fundamental liberties that were taken away by the passage of SB277. We have signed T. Matthew Phillips, Esq., to litigate against the state to strike down this unconstitutional law.

We are currently not a non profit. Our purpose is to collect money to litigate against SB277.

Note that there are ethical considerations for any attorney using funds raised from third parties.  Such a firm’s fiduciary duty must only run to the client(s), if any, that it would represent to challenge SB277 and such representation cannot be influenced by third parties. Hence, if sufficient funds are raised and hence not refunded, they shall be an irrevocable gift that does not entitle the gifter to any rights, legal representation, or influence, in any manner whatsoever, related in the representation of any client(s) of any firm using these funds. The only client to whom such firm will owe a fiduciary duty, whose direction it will follow, and whose interests it is fiduciary bound to protect will be the actual plaintiffs on whose behalf the firm may seek to challenge SB277. Such are the ethical restrictions that any such law firm must abide.

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