18.  On March 23, 2014, the World Health Organization (“WHO”) announced an  outbreak of Ebola in West Africa. After the first confirmed case in March 2014, Ebola spread  rapidly throughout Guinea, Liberia, and Sierra Leone.    20.  By fall 2014, doctors were diagnosing hundreds of new cases each week in West  Africa. Over the twenty-two months of the epidemic, there were more than 28,000 cases of Ebola  in these three countries and more than 11,000 deaths.   2014 Ebola Crisis and Connecticut Response   21.  In response to the epidemic, thousands of volunteers from around the world  traveled to Guinea, Liberia, and Sierra Leone to provide critical medical assistance and share  other forms of technical expertise. Community organizations, including Plaintiff LCAC, and  churches run by Liberian immigrants in the United States, like Plaintiff Bishop Yalaratai’s,  raised funds to support humanitarian aid for Liberians confronting the crisis.   22.  Despite the considerable number of volunteers and staff traveling to and from  these countries, the Centers for Disease Control and Prevention (“CDC”) noted that there were  fewer than forty cases outside of Guinea, Liberia, and Sierra Leone during the crisis.   23.  On August 22, 2014, the CDC publicly released guidance for monitoring people  potentially exposed to Ebola. For asymptomatic individuals returning from West Africa with “no  risk” or “low risk” of exposure, the CDC recommended only self-monitoring or active  monitoring for twenty-one days and recommended no movement restrictions or quarantine.    24.  Even for individuals in the “high risk” exposure level category—such as those  who had had direct, unprotected contact with the bodily fluids of an Ebola patient or a dead  body— the CDC only recommended “controlled movement” for twenty-one days so long as such  individuals were asymptomatic. Under controlled movement, individuals had to inform public  health officials of their intended travel and avoid long-distance public transportation.    26.  On October 7, 2014, Defendant Malloy issued an order declaring a public health  emergency for the State of Connecticut (hereinafter “Emergency Declaration”). The legal effect  of this declaration under state law, as stated in quarantine orders later issued, was to authorize  Defendant Mullen, the Connecticut Commissioner of Public Health, to direct the isolation or  quarantine of individuals whom she “reasonably believe[d] to have been exposed to, infected  with, or otherwise at risk of passing the Ebola virus.”    27.  According to the CDC, “isolation” is the separation of individuals who are sick  with a contagious disease from those who are not sick. “Quarantine” is the separation of  asymptomatic individuals exposed to a contagious disease to see if they become sick.   28.  On October 8, 2014, the CDC announced a safety plan, in collaboration with the  Department of Homeland Security (“DHS”), to protect the United States from an Ebola outbreak.   29.  Under the plan, DHS directed persons entering the United States from Guinea,  Liberia, and Sierra Leone to one of five ports of entry where it undertook specialized screenings.  Trained staff observed travelers for signs of illness, asked them a series of health and exposure  questions, and took their temperatures. CDC quarantine station public health officers evaluated  travelers with fever or other symptoms, as well as any travelers whose health questionnaires  revealed possible Ebola exposure.   30.  When officers determined that passengers required further evaluation or  monitoring, federal officers referred those travelers to the appropriate state or local public health  authority. Travelers with no symptoms, fever, or a known history of exposure received health  information for self-monitoring and were approved to exit the airport.    32.  By contrast, the August 22, 2014 CDC guidance, the federal public health  recommendations for best practices at the time, stated that states should impose “no movement  restrictions” for asymptomatic individuals who had been “in a country in which an EVD  [(“Ebola Virus Disease”)] outbreak occurred within the past twenty-one days and ha[d] no  exposure.” The overwhelming consensus in the scientific community at the time was, and  remains, that asymptomatic individuals cannot transmit Ebola and do not require quarantine.    33.  Defendants Mullen and Malloy knew that the “[p]eople under quarantine [we]re  not sick and not a risk to public health,” as a DPH spokesman repeatedly stated in October 2014,  but nevertheless imposed and maintained their quarantine under the DPH Plan. (Exhibit A).  Defendant Mullen approved this statement.   34.  Defendants Mullen and Malloy knew that their policy and practice of quarantine  was retrograde and ill-suited to contemporary public health challenges. In an email message,  DPH epidemiologist Matt Cartter described Connecticut’s legal definition of quarantine as “very  19th century, making 21st century quarantine options difficult to implement.”    36.  The Revised DPH Plan also required DPH to conduct an individualized risk  assessment for such travelers before deciding whether to take steps beyond active mandatory  monitoring. Local health department staff or DPH epidemiologists were to interview travelers  about their travel history and potential exposure to Ebola. Epidemiological experts at DPH would  assess this information and its quality before making a decision. On information and belief,  Defendants failed to reconsider Plaintiffs’ quarantine orders under the Revised DPH Plan, and  required Plaintiffs to remain in quarantine for an additional three to twelve days.   37.  On November 7, 2015, December 29, 2015, and January 14, 2016, the WHO  declared Sierra Leone, Guinea, and Liberia Ebola-free, respectively.   38.   According to expert public health opinion, Liberia, Sierra Leone, and Guinea  remain at high risk of future Ebola outbreaks and this area could potentially face another large  outbreak.    39.  According to the DPH Ebola Preparedness and Response webpage, last modified  January 7, 2016, “Governor Malloy’s declaration on October 7, 2014 of a public health  emergency for Connecticut for the duration of the Ebola epidemic in West Africa remains in  effect.”    41.  Despite the evolution from the DPH Plan to the Revised DPH Plan to current  policies, Defendants have maintained a policy, practice, custom, and usage of failing to impose  the least restrictive means to prevent Ebola infections; failing to base their decisions in science  and evidence rather than politics and fear; failing to give quarantined people timely notice in  writing, or ever; failing to affirmatively seek judicial review, where the state would bear the  burden to establish the necessity of quarantine by clear and convincing evidence; and failing to  provide for the welfare and safety of those subject to quarantine (hereinafter “Defendants’  quarantine policies and practice”).    42.  Pursuant to Defendants’ quarantine policies and practice, and regardless of the  shift from the DPH Plan to the Revised DPH Plan to current policy, Defendants have repeatedly  maintained quarantines of individuals they knew “[we]re not sick and not a risk to public health,”  and reserve their right to do so in the future.   43.  Because the risk of a future Ebola outbreak in West Africa is high, because  Defendants reserve the authority to issue scientifically unjustified and unlawful quarantine orders  pursuant to Defendant Malloy’s unrescinded emergency declaration, and because it is highly  likely that Defendants will again overreact to a future Ebola outbreak, Plaintiffs and other  present and future travelers from Liberia, Guinea, and Sierra Leone are at real and immediate  risk of being subject to Defendants’ quarantine policies and practice.  Quarantine of Public Health Students Boyko and Skrip   45.  Boyko and Skrip left John F. Kennedy International Airport in New York on  September 17, 2014 and arrived in Monrovia, Liberia on September 18, 2014.    46.  While in Liberia, Boyko and Skrip volunteered with the Ministry of Health and  Social Welfare to create a computerized Ebola-case tracking system. During their stay, they  developed a cloud-based Android app that improved contact tracing of Ebola cases in Liberia  and provided a computer interface for visualizing this data.   47.  Boyko and Skrip did not volunteer in a healthcare capacity and did not treat  patients. They did not have contact with any Ebola-symptomatic individuals.   48.  While in Liberia, Boyko and Skrip worked in the Ministry of Health and Social  Welfare’s government building. They ate breakfast and dinner at their hotel and brought food  from the hotel to work with them for lunch. They were transported in a private car between the  hotel and the government building in order to avoid contact with people with Ebola symptoms.   49.  Boyko and Skrip took numerous additional precautions while in Liberia,  including observing a “no touching” policy, not using public transportation, frequently cleaning  their shoes by stepping on foam blocks soaked in chlorine solution, and frequently washing their  hands with sanitizer or chlorine solution.    51.  Boyko felt better after approximately two days, at which point Boyko and Skrip  began planning their return to Connecticut.  As a condition of compensating Boyko and Skrip for  a replacement flight, Yale’s travel medical insurance company required Boyko to be tested for  Ebola by a medical professional.    52.  In the course of revising their travel plans, Boyko and Skrip had numerous  communications with Yale faculty and staff.    53.  On October 6, 2014, Boyko tested negative for Ebola. He received a handwritten  letter confirming the negative test from a United States Army colonel supervising the testing lab.  Shortly thereafter, Boyko and Skrip scheduled a return flight to the United States.    54.  Before leaving, Boyko and Skrip learned that one person who sometimes spent  time at their hotel, a freelance cameraman, later developed symptoms of Ebola. Out of an  abundance of caution, Boyko and Skrip spoke with local CDC agents to be sure that they were  not at risk as a result. The CDC representatives assured Boyko and Skrip that this was a “no risk”  interaction as the cameraman had not become contagious until after the last time they saw him.    55.  Early in the morning of October 11, 2014, Boyko and Skrip departed Monrovia,  Liberia by plane. Upon arrival at John F. Kennedy International Airport on October 11, 2014,  they underwent the CDC entry screening procedures for Ebola. Both Boyko and Skrip were ruled  medically fit under those procedures. Officials of the U.S. Department of Homeland Security  allowed them both to enter the United States.     57.  After returning to New Haven that day, Boyko and Skrip monitored themselves  for symptoms of Ebola. As part of their monitoring efforts, Boyko and Skrip took their  temperatures twice a day and emailed results to staff at the Yale Health Center.    58.  On the morning of October 15, Boyko’s temperature rose to 100.1 degrees  Fahrenheit. Boyko informed a member of Yale Health. Although he felt fine, the Yale Health  Center and Yale-New Haven Hospital jointly decided to transport him from his home to the  hospital.    59.  At approximately 11 p.m. on October 15, an ambulance arrived to take Boyko to  Yale-New Haven Hospital.    60.  On information and belief, Yale Health, Yale-New Haven Hospital, or other Yale  officials informed state and city public health officials of Boyko’s hospital admission.   61.  After Boyko was admitted to the hospital, doctors took samples of his blood and  sent them to the CDC and the Massachusetts State Public Health laboratory for Ebola testing.    62.  While in the Medical Intensive Care Unit, Boyko’s fever subsided.   63.  On October 16, 2014, the day after Boyko arrived at the hospital, Plaintiff Skrip  received a call from the City of New Haven Health Department’s epidemiologist, Amanda  Durante. Durante informed Skrip that the City of New Haven would begin “mandatory active  monitoring” of Skrip.  This meant the City would call twice a day at which time Skrip was  required to take and report her temperature.   64.  Later that day, October 16, 2014, Boyko’s first U.S. test results returned negative  for Ebola.   66.  On October 17, the CDC confirmed that Boyko’s blood tested negative for Ebola.    67.  Upon receiving the blood test result, doctors at Yale-New Haven Hospital told  Boyko that he was healthy, without symptoms, and had no reason to take any kind of further  precautions. His doctors removed their protective gear and shook his hand. They joked that  Boyko was the only person in New Haven they could definitively say did not have Ebola.   68.  Shortly thereafter, on October 17, Defendant Mullen issued a quarantine order,  requiring that Boyko be confined in his home for twenty-one days, or up to and including  October 30. The order was backdated to October 10 and signed by Defendant Mullen. Defendant  Mullen, as authorized by Defendant Malloy, caused the order to be delivered to Yale-New Haven  hospital, and upon information and belief, directed medical staff there to serve the order on  Boyko. A copy of the order is attached as Exhibit B.    69.  The quarantine order did not mention that Boyko had tested negative for Ebola  three times.    70.  The order stated that an individual who violates his or her quarantine may be  subject to sanctions, including imprisonment and fines.   71.  Late in the afternoon of October 18, a plainclothes hospital security officer drove  Boyko to his apartment in New Haven in an unmarked car.   73.  On that joint call, Defendants Malloy and Mullen caused Durante and Defendant  Malloy’s staff to state that Skrip was forbidden from leaving her apartment. At the time of her  quarantine, Defendants failed to provide or cause others to provide Skrip notice of her rights,  information about how to challenge the quarantine, or a written notice of quarantine.    74.  Skrip informed Maria Bouffard, the Director of Emergency Management at Yale  University, that she had never received a quarantine order. On or around October 22, 2014, five  days after Defendant Mullen caused Skrip to be informed orally that she was subject to  quarantine, and twelve days after the effective date of the order, someone from the City of New  Haven provided a copy of the order to Skrip. A copy of the order is attached as Exhibit C.   75.  The order stated that an individual who violates his or her quarantine may be  subject to sanctions, including imprisonment and fines.   76.  On information and belief, Defendant Mullen, as authorized by Defendant  Malloy, through the State’s quarantine order, required the New Haven Police Department  (“NHPD”) to enforce the quarantines against Boyko and Skrip. NHPD stationed a police officer  outside the apartments of both Boyko and Skrip twenty-four hours per day, during Defendants’  quarantine of them. On information and belief, at least one NHPD officer told Skrip’s neighbors  that an individual with Ebola was living in her building.   78.  No state or city agency provided assistance to ensure Boyko or Skrip had  adequate food, toiletries, and other life necessities. Neither Skrip nor Boyko was able to shop for  food or other essentials after returning from Liberia and before being placed under quarantine.    79.  Ryan was able to eat only because Bouffard delivered Visa gift cards that enabled  him to purchase needed supplies. Under orders from Defendants, NHPD allowed Boyko to step  outside to pick up such deliveries, but only if he immediately returned to his apartment.    80.  After an NHPD officer confronted a friend who dropped off food and sanitary  supplies on Skrip’s fire escape, Skrip was too afraid to order additional food with the Visa gift  cards provided by Yale.    81.  By their actions, Defendants transformed the homes of Skrip and Boyko into their  prisons. Skrip and Boyko were unable to leave and police officers constantly stood watch outside  their doors.    82.  While in quarantine, Boyko became depressed. He was cut off from family,  friends, and colleagues.    83.  During quarantine, Boyko was unable to spend time with his young son, of whom  Boyko shares custody. Even following Boyko’s quarantine, his former wife had concerns about  allowing him to spend time with his son, due to her perception that the State considered Boyko a  danger to others.     84.  Boyko was also unable to see his girlfriend, who the quarantine order prohibited  from entering their shared apartment.   86.  Despite implementation of the Revised DPH Plan on October 27, Defendant  Mullen did not review or cause the review of the quarantine orders against Boyko or Skrip. On  information and belief, Plaintiffs never benefited from any such individualized assessment by  Defendant Mullen, local health department staff, or an epidemiologist from DPH.   87.  Defendant Mullen, as authorized by Defendant Malloy, originally ordered Boyko  quarantined through October 30, 2014. However, Boyko requested to be released a day early  given that the state’s power to quarantine, absent a renewed order, is limited to 20 days.  Conn.  Gen. Stat. § 19a-131b(c).    88.  Shortly thereafter, Boyko received an email from state officials forwarded to  Boyko by Bouffard saying the quarantine would end at 12:01 a.m. on October 30, 2014. Late in  the evening of October 29, 2014, NHPD withdrew their officers stationed outside the homes of  Boyko and Skrip, and at 12:01 a.m. on October 30, 2014, Defendants Mullen and Malloy  released Boyko and Skrip from quarantine.    89.  Even after the quarantine ended, Boyko continued to grapple with the after effects  of the isolation and quarantine.     90.  Shortly after the quarantine, Boyko and his girlfriend broke up, in significant part  due to the stress of the quarantine. His relationship with his former wife has been strained since  their custody disagreement during the quarantine.   92.  Skrip also grappled with many adverse consequences during and after the  quarantine. The quarantine interfered with her graduate research work and her research assistant  position at Yale University. The quarantine also prevented performance of her duties as a  volunteer co-director for a department of the Haven Free Clinic. The experience of the  quarantine strained and continues to strain Skrip’s professional and volunteer relationships.   93.  Defendants Malloy and Mullen knew or should have known that their quarantine  of Boyko and Skrip was scientifically unjustified and not the least restrictive means to protect  public health; that Defendants failed to provide essential supplies to Boyko and Skrip; that  Defendants imposed the quarantine orders without a state-initiated judicial probable cause  hearing before or immediately after Defendants seized Boyko and Skrip; and that the quarantine  of Skrip was instituted without timely notice.   94.  Defendants Malloy and Mullen knew or should have known that their quarantine  of Boyko and Skrip discriminated against Plaintiffs due to Plaintiffs’ perceived risk of illness by  severely diminishing their everyday life activities including family relations, social contacts,  work options, economic independence, educational advancement, and cultural enrichment.   95.  Defendant Mullen knew or should have known that her reckless conduct in  ordering and carrying out Boyko and Skrip’s quarantines would unlawfully detain and confine  them, cause their reasonable apprehension of force, interrupt their ability to perform their work,  and inflict emotional distress on them.   Quarantine of Mensah-Sieh Family    97.  Plaintiff Mensah-Sieh (who is the sister of Nimley-Phillips), her husband Plaintiff  Nathaniel Sieh, and their four children Emmanuel Kamara, Victor Sieh, B.D., and S.N., lived in  Sinkor, Monrovia in Liberia until October 2014. In Sinkor, Nathaniel Sieh worked in  immigration for the government and Mensah-Sieh worked for Global Bank and at St. Joseph’s  Catholic Hospital.   98.  Prior to the Ebola outbreak, the Mensah-Sieh family applied to the U.S. Diversity  Visa Lottery and in June 2013 learned that they would be awarded visas. Plaintiffs were excited  by the opportunity to emigrate to the U.S. to improve their lives and career prospects and to  provide educational opportunities for their children.  