• Skip to content
  • Skip to primary sidebar
Bell Nunnally & Martin LLP

News/Events

Alerts | December 9, 2021

Federal Contractor Vaccine Mandate Blocked Nationwide

On September 9, President Biden signed Executive Order 14042 (Ensuring Adequate Safety Protocols for Federal Contractors) (“Federal Contractor Mandate”). The Federal Contractor Mandate required covered parties who contract with the federal government to comply with COVID-19 safeguards in the workplace. These safeguards applied to all covered federal contractors and flowed down to subcontractors.

The Federal Contractor Mandate required:

  • COVID-19 vaccination of all covered contractor employees, except where the employee was legally entitled to an accommodation; 
  • Compliance with certain masking and physical distancing guidelines; and
  • Designation of an individual to coordinate of workplace safety efforts.

Several states challenged the enforceability of the Federal Contractor Mandate, arguing that Congress did not clearly authorize the issuance of this type of mandate. In late November, the Federal Contactor Mandate was blocked through litigation in Kentucky, Ohio and Tennessee.

On December 7, a federal court in Georgia also issued a nationwide injunction halting enforcement of the Federal Contractor Mandate throughout the country.

What Does This Mean for Businesses Who are Federal Contractors or Subcontractors?

As the litigation proceeds through appellate courts, covered federal contractors and subcontractors are left to speculate what this could mean for their policies and requirements in the future. There are presently no compliance obligations for federal contractors or subcontractors under the Federal Contractor Mandate. However, private companies still have the right to mandate that their employees be vaccinated against COVID-19, as long as they provide exemptions for sincerely held religious beliefs and medical disabilities.

What Now?

If they haven’t already, businesses should still prepare and implement a COVID-19 prevention policy that models the latest guidance from the Centers for Disease Control and Prevention (CDC) and the Occupational Safety and Health Administration (OSHA) on how to prevent the spread of COVID-19. Any standard prevention policy should include safety protocols, as well as isolation and quarantine protocols.

Compliance obligations surrounding vaccine mandates continue to change as various government agencies and courts grapple with the legal issues these mandates present. Businesses should continue to monitor the latest developments on COVID-19 compliance to ensure they are abreast of current obligations and risks.

Primary Sidebar

Related Attorneys

  • Alana K. Ackels

    Alana K. Ackels

    Partner

    aackels@bellnunnally.com
    214-740-1412
  • Katie Beaird

    Katie Beaird

    Partner

    kbeaird@bellnunnally.com
    214-740-1478
  • Thomas L. Case

    Thomas L. Case

    Of Counsel

    tcase@bellnunnally.com
    214-740-1422
  • Sydnie A. Shimkus

    Sydnie A. Shimkus

    Partner

    sshimkus@bellnunnally.com
    214-740-1490
  • John D. Smart

    John D. Smart

    Partner

    jsmart@bellnunnally.com
    214-740-1475
  • Jay M. Wallace

    Jay M. Wallace

    Partner

    jwallace@bellnunnally.com
    214-740-1407

Related Practices

  • Labor and Employment
Stay in the know...
Don’t miss anything — Subscribe to our email list!
2323 Ross Avenue, Suite 1900, Dallas, Texas 75201 | 214.740.1400
© 2025 Bell Nunnally & Martin LLP All Rights Reserved
  • Sitemap
  • Disclaimer
  • Privacy Policy
  • Client Pay
legalink logo Site by
We use cookies on our website to give you the most relevant experience by remembering your preferences and repeat visits. By clicking “Accept All”, you consent to the use of ALL the cookies. However, you may visit "Cookie Settings" to provide a controlled consent.
Cookie SettingsAccept All
Manage consent

Privacy Overview

This website uses cookies to improve your experience while you navigate through the website. Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may affect your browsing experience.
Necessary
Always Enabled
Necessary cookies are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.
CookieDurationDescription
cookielawinfo-checkbox-analytics11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checkbox-functional11 monthsThe cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checkbox-necessary11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-others11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-performance11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy11 monthsThe cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.
Functional
Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features.
Performance
Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.
Analytics
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.
Advertisement
Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.
Others
Other uncategorized cookies are those that are being analyzed and have not been classified into a category as yet.
SAVE & ACCEPT
  • People
  • Practices
  • Industries
  • News/Events
  • Contact Us
  • About Us
  • Clients
  • Careers
  • Client Pay