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Saint Louis University School of Law
Scholarship Commons
All Faculty Scholarship 2021
Systemic Racism, the Government’s Pandemic Response, and Racial Inequities in COVID-19
Ruqaiijah Yearby Saint Louis University School of Law Seema Mohapatra Indiana University Robert H. McKinney School of Law
Follow this and additional works at: https://scholarship.law.slu.edu/faculty Part of the Civil Rights and Discrimination Commons, and the Health Law and Policy Commons
Recommended Citation Yearby, Ruqaiijah and Mohapatra, Seema, Systemic Racism, the Government’s Pandemic Response, and Racial Inequities in COVID-19. Emory Law Journal, Forthcoming 2021, Saint Louis U. Legal Studies Research Paper No. 2021-02.
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No. 2021-02
Systemic Racism, the Government’s Pandemic Response, and Racial Inequities in COVID-19
Ruqaiijah Yearby
Saint Louis University - School of Law
Seema Mohapatra
Indiana University Robert H. McKinney School of Law
Emory Law Journal, Forthcoming 2021

SYSTEMIC RACISM, THE GOVERNMENT’S PANDEMIC RESPONSE, AND RACIAL INEQUITIES IN COVID-19
Ruqaiijah Yearby and Seema Mohapatra*
ABSTRACT During the COVID-19 pandemic, federal and state governments have ignored racial and ethnic minorities’ unequal access to employment and health care, which has resulted in racial inequities in COVID-19 infections and deaths. In addition, they have enacted laws that further exacerbate these inequities. Consequently, many racial and ethnic minorities are employed in low-wage essential jobs that lack paid sick leave and health insurance. This lack of benefits causes them to go to work even when they are sick and prevents them from receiving appropriate medical treatment. As a result, racial and ethnic minorities have disproportionately been infected and died from COVID-19. Although these actions seem race “neutral,” they exemplify systemic racism, wherein racial and ethnic minorities are deemed inferior to white people, and thus do not receive the same access to resources, such as employment and health care. This essay illustrates how systemic racism has resulted in racial inequities in COVID-19 infections and deaths through case studies in employment and health care. Using the health justice framework, it concludes with suggestions to eradicate systemic racism, redress harm, and engage community in implementing an equitable pandemic response.

TABLE OF CONTENTS

INTRODUCTION

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I. COVID-19, SYSTEMIC RACISM, AND HEALTH JUSTICE

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A. Systemic Racism and Racial Inequities in COVID-19

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* Ruqaiijah Yearby, Professor of Law and Member of the Center for Health Law Studies, Saint Louis University, School of Law; Co-Founder and Executive Director, Institute for Healing Justice, Saint Louis University; J.D., Georgetown University Law Center; M.P.H. Health Policy and Management, Johns Hopkins School of Public Health; B.S. Honors Biology, University of Michigan. Seema Mohapatra, Professor of Law at St. John’s University School of Law; J.D., Northwestern University School of Law; M.P.H. Chronic Disease Epidemiology, Yale University School of Public Health; B.A. Natural Sciences, with a minor in Women’s Studies, Johns Hopkins University. We would like to thank Crystal Lewis, Health Equity and Policy Fellow, Saint Louis University, School of Law, for her assistance, as well as the student editors of Emory Law Journal.

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B. Health Justice

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II. SYSTEMIC RACISM IN EMPLOYMENT

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A. Systemic Racism, Political Decisions, and Racial Inequities in COVID-19 16

B. Systemic Racism, Failure to Enforce Health and Safety Laws, and Racial

Inequities in COVID-19

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C. Systemic Racism, Emergency Preparedness Response, and Racial Inequities in

COVID-19

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D. Health Justice: Eradicating Systemic Racism in Employment

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III.SYSTEMIC RACISM IN HEALTH CARE

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A. Systemic Racism, Hospital Care, and Racial Inequities in COVID-19

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B. Systemic Racism, Vaccination Decisions, and Racial Inequities in COVID-19 43

C. Systemic Racism, Physician Care, and Racial Inequities in COVID-19

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D. Health Justice: Eradicating Systemic Racism in Health Care

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CONCLUSION

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INTRODUCTION In June 2020, agricultural workers at a pistachio farm in Wasco, California, many of whom were racial and ethnic minorities, didn’t know workers had tested positive for COVID-19 until they learned it from other workers and the media. By that time, 150 workers and 65 family members tested positive.1 After the announcement, the farm started to make masks available free of cost, whereas before they were charging workers $8 per
1 Associated Press, Farmworkers at Central California Pistachio Farm Strike After Dozens Test Positive for the Coronavirus, L.A. TIMES (June 25, 2020, 5:29PM), https://www.latimes.com/california/story/2020-06-25/farmworkers-at-central-californiapistachio-strike-after-dozens-test-positive-for-the-coronavirus; Jacqueline Garcia, Dozens of Pistachio Plant Workers Infected with COVID-19, KQED (July 6, 2020), https://www.kqed.org/news/11827498/dozens-of-pistachio-plant-workers-infected-withcovid-19; Dale Yurong, Protest Held After Dozens of Farmworkers Test Positive for COVID-19 at Wasco Packing House, ABC30 FRESNO (July 16, 2020), https://abc30.com/wasco-coronavirus-covid-packing-house-primex-farms/6321004/.

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mask.2 In California, a COVID-19 outbreak at the Farmer John pork processing plant began in 2020 and has continued for nearly a year, “with more than 300 cases reported in January (2021) alone.”3 An Optum nurse asked Latinos for additional identification, made them wait for appointments
and test results, and called the police saying undocumented immigrants were seeking testing at the Elkhart County, Indiana, health care site.4 In North
Carolina, it is alleged that hospitals were sending away some Latinos even though their COVID-19 symptoms were serious enough to be admitted to the hospital.5 Black teacher Rana Zoe Mungin was twice denied a COVID-19 test and her symptoms were dismissed by an EMT as a panic attack.6 She
later passed away from COVID-19 at Brooklyn’s Brookdale Hospital. Deborah Gatewood, a Black 63-year-old Detroit health care worker, was
turned away four times with COVID-19 symptoms from Beaumont Hospital, where she had worked for 31 years.7 These racial inequalities in employment
and health care are associated with racial inequities in COVID-19 infections and deaths.
Historically, the federal and state government’s legal and policy response to pandemics has ignored these racial inequalities in employment and health care, which are linked to racial inequities in infection and death.8 During the

2 Associated Press, supra note 1. 3 Leah Douglas & Georgia Gee, A COVID Outbreak at a California Meatpacking Plant Started a Year Ago—and Never Went Away, MOTHER JONES (Mar. 16, 2021), https://www.motherjones.com/food/2021/03/a-covid-outbreak-at-a-california-meatpackingplant-started-a-year-ago-and-never-went-away/. 4 Shelia Selman, Company Apologizes for Discrimination Against Latinos at Goshen COVID-19 Testing Site, GOSHEN NEWS (July 3, 2020), https://www.goshennews.com/news/company-apologizes-for-discrimination-againstlatinos-at-goshen-covid-19-testing-site/article_10ff0bf2-bc8a-11ea-b0c6eb3aed4bb58c.html. 5 Lynn Bonner, State Adviser: Some NC Latinos Sick with COVID-19 Are Sent Home from Hospitals, NEWS & OBSERVER (July 16, 2020, 5:32 PM), https://www.newsobserver.com/news/coronavirus/article244272717.html. 6 Arielle Mitropoulos & Mariya Moseley, Beloved Brooklyn Teacher, 30, Dies of Coronavirus After She Was Twice Denied A COVID-19 Test, ABC NEWS (Apr. 28, 2020, 7:39 PM), https://abcnews.go.com/Health/beloved-brooklyn-teacher-30-dies-coronavirusdenied-covid/story?id=70376445; Shamar Walters & David K. Li, New York City Teacher Dies from Covid-19 After She Was Denied Tests, Family Says, NBC NEWS (Apr. 29, 2020, 4:42 PM), https://www.nbcnews.com/news/us-news/new-york-city-teacher-dies-covid-19after-she-was-n1195516. 7 John Eligon & Audra D.S. Burch, Questions of Bias in Covid-19 Treatment Add to Mourning for Black Families, N.Y. TIMES (May 20, 2020), https://www.nytimes.com/2020/05/10/us/coronavirus-african-americans-bias.html; Janelle Griffith, Detroit Health Care Worker Dies After Being Denied Coronavirus Test 4 Times, Daughter Says, NBC NEWS (Apr. 27, 2020, 8:33 PM), https://www.nbcnews.com/news/usnews/detroit-health-care-worker-dies-after-being-denied-coronavirus-test-n1192076. 8 Ruqaiijah Yearby, Structural Racism and Health Disparities: Reconfiguring the

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COVID-19 pandemic, the federal and state government has not only continued to disregard these inequalities in employment and health care, but they have also enacted laws and implemented policies that further exacerbate these inequalities, harming racial and ethnic minorities.9 For example, prior to May 2020, Iowa’s policy was to publicly confirm COVID-19 cases at businesses. However, when major COVID-19 outbreaks at meat and poultry processing plants, which were predominately staffed by racial and ethnic minorities and undocumented immigrants, occurred in May 2020, officials would only confirm outbreaks at businesses if 10% of a company’s employees tested positive and reporters asked about the outbreaks.10 This hampered reporting of cases and local officials’ efforts to control infections as the state even limited information given to local officials, including Perry city officials, where it was later learned that 58% of employees tested positive at a Tyson plant in Perry city.11 The failure to report cases left workers vulnerable to the workplace exposure of COVID-19. Although these laws and policies seem race “neutral,” they disproportionately harm racial and ethnic minorities, and are a result of systemic racism.
Systemic racism is a social system wherein the racial group in power creates a racial hierarchy that deems other racial groups to be inferior and grants those “inferior races” fewer resources and opportunities.12 In the

Social Determinants of Health Framework to Include the Root Cause, 48 J.L., MED. & ETHICS 518, 520 (2020); Ruqaiijah Yearby & Seema Mohapatra, Law, Structural Racism, and the COVID-19 Pandemic, 7 OXFORD J.L. & BIOSCIENCES, 1, 4 (2020); Philip Blumenshine, Arthur Reingold, Susan Egerter, Robin Mockenhaupt, Paula Braveman & James Marks, Pandemic Influenza Planning in the United States from a Health Disparities Perspective, 14 EMERGING INFECTIOUS DISEASES 709, 709–10 (2008); Supriya Kumar, Sandra Crouse Quinn, Kevin H. Kim, Laura H. Daniel & Vicki S. Freimuth, The Impact of Workplace Policies and Other Social Factors on Self-Reported Influenza-Like Illness Incidence During the 2009 H1N1 Pandemic, 102 AM. J. PUB. HEALTH 132, 134, 135–39 (2012); Monica Schoch-Spana, Nidhi Bouri, Kunal J. Rambhia & Ann Norwood, Stigma, Health Disparities, and the 2009 H1N1 Influenza Pandemic: How to Protect Latino Farmworkers in Future Health Emergencies, 8 BIOSECURITY & BIOTERRORISM: BIODEFENSE STRATEGY, PRAC. & SCI. 243, 253 (2010). In this essay, the term racial inequities includes inequities experienced by ethnic minorities and undocumented immigrants.
9 Yearby & Mohapatra, supra note 8, at 2–4. 10 Brianne Pfannenstiel, Iowa Officials Won’t Disclose Coronavirus Outbreaks at Meatpacking Plants Unless Media Asks, DES MOINES REG. (May 28, 2020), https://www.desmoinesregister.com/story/news/politics/2020/05/27/iowa-wont-disclosecovid-19-outbreaks-businesses-unless-media-asks-kim-reynolds/5267413002/. 11 Id. 12 David R. Williams, Jourdyn A. Lawrence & Brigette A. Davis, Racism and Health: Evidence and Needed Research, 40 ANN. REV. PUB. HEALTH 105, 107 (2019); SEAN ELIAS & JOE R. FEAGIN, RACIAL THEORIES IN SOCIAL SCIENCE: A SYSTEMIC RACISM CRITIQUE 267 (2016). In this Essay we define racism broadly to include the problems experienced by

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United States, this racial hierarchy13 has become embedded in the government’s pandemic response, often limiting racial and ethnic minorities’
equal access to key resources such as employment benefits and protections, as well as COVID-19 testing, health care treatment, and vaccines. As a result,
racial and ethnic minorities face increased risk of workplace exposure to COVID-19 because they work in low-wage, essential jobs that do not provide
the option to work from home, and they cannot afford to miss work even when they are sick.14 In fact, research shows that only 16.2% of Latinos and 19.7% of Blacks have jobs that they perform from home.15 This means that only 1 in 6 Latinos and 1 in 5 Black workers can telework.16 Furthermore, the
jobs often do not provide health insurance, and thus, racial and ethnic minorities lack access to appropriate testing and treatment during the COVID-19 pandemic.17 “Blacks remained 1.5 times more likely to be uninsured than whites from 2010 to 2018,” and Latinos have an uninsured rate over 2.5 times higher than the rate for whites.18 Due to increased workplace exposure and lack of access to treatment, racial and ethnic minorities have disproportionately been infected and died from COVID-19.19
To put an end to racial inequities in COVID-19 infections and deaths, the
government should adopt the health justice framework, which provides a community-informed agenda for transforming the government’s emergency
preparedness responses to eradicate systemic racism and achieve health equity. Based in part on principles from the reproductive justice,

ethnic minorities. We do this because courts have not always been clear about how they treat these ethnic minorities differently than racial minorities. See Khiara M. Bridges, The Dangerous Law of Biological Race, 82 FORDHAM L. REV. 21, 69–75 (2013).
13 Eduardo Bonilla-Silva, Rethinking Racism: Toward a Structural Interpretation, 62(3) AM. SOCIO. REV. 465–80 (1997).
14 Id. at 6. 15 Elise Gould & Heidi Shierholz, Not Everybody Can Work from Home: Black and Hispanic Workers Are Much Less Likely to Be Able to Telework, ECON. POL’Y INST., WORKING ECON. BLOG (Mar. 19, 2020, 1:15 PM), https://www.epi.org/blog/black-andhispanic-workers-are-much-less-likely-to-be-able-to-work-from-home/. 16 Id. Research also shows how COVID-19 workplace exposure varies by race and ethnicity, with racial and ethnic minorities disproportionately exposed to COVID-19 in the workplace. Id.; LISA DUBAY, JOSHUA AARONS, K. STEVEN BROWN & GENEVIEVE M. KENNEY, HOW RISK OF EXPOSURE TO THE CORONAVIRUS AT WORK VARIES BY RACE AND ETHNICITY AND HOW TO PROTECT THE HEALTH AND WELL-BEING OF WORKERS AND THEIR FAMILIES 2 (2020), https://www.urban.org/sites/default/files/publication/103278/how-riskof-exposure-to-the-coronavirus-at-work-varies.pdf. 17 Yearby, supra note 8, at 4. 18 Samantha Artiga, Kendal Orgera & Anthony Damico, Changes in Health Coverage by Race and Ethnicity Since the ACA, 2010-2018, KAISER FAM. FOUND. (Mar. 5, 2020), https://www.kff.org/racial-equity-and-health-policy/issue-brief/changes-in-healthcoverage-by-race-and-ethnicity-since-the-aca-2010-2018. 19 Yearby & Mohapatra, supra note 8, at 4–7, 10–16.

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environmental justice, food justice, and civil rights movements, the health justice framework offers three principles to improve the government’s
emergency preparedness response: (1) structural remediation; (2) financial supports and accommodations; and (3) community engagement and (3) empowerment. First, emergency preparedness laws and policies must address systemic racism by structurally changing the systems that cause racial inequalities in access to key resources.20 Second, these emergency preparedness laws and policies must be accompanied by financial supports
and protections, so that racial and ethnic minorities can stay home when they are sick.21 Third, racial and ethnic minorities must be engaged and
empowered as leaders in the development and implementation of emergency preparedness laws and policies to ensure that the laws address their needs.22
By adopting these three steps, the government can improve their emergency preparedness response by not only protecting racial and ethnic minorities
from harm, but also by providing material and institutional support to address racial inequities in COVID-19 infections and deaths.23
Many vulnerable communities,24 including low-income, disabled, and the elderly, have experienced inequities in COVID-19 infections and deaths, in
this Essay, we use racial and ethnic minorities as an illustrative example of how the federal and state government’s legal and policy response to

20 Angela P. Harris & Aysha Pamukcu, The Civil Rights of Health: A New Approach to Challenging Structural Inequality, 67 UCLA L. REV. 758, 806 (2020) (“[H]ealth justice . . . places subordination at the center of the problem of health disparities.”); Lindsay F. Wiley, Health Law as Social Justice, 24 CORNELL J.L. & PUB. POL’Y 47, 87 (2014) (“Health justice naturally expands the focus beyond access to health care to address the community conditions that play such an important role in determining health disparities.”); Id. at 85 (“[Achieving health justice] will take organizing from the ground up; social change that transforms the current systems of neglect, bias, and privilege into systems—policies, practices, institutions—that truly support health[y] communities for all.” (quoting a now-inactive website developed by The Praxis Project)).
21 Wiley, supra note 20, at 95–96 (“[I]nterventions [grounded in health justice] reflect collective responsibility for health rather than individualistic interventions aimed at urging people to change their behaviors without necessarily making it easier for them to do so.”).
22 Harris & Pamukcu, supra note 20, at 765 (describing “the emergent ‘health justice’ movement [as] a framework that places the empowerment of marginalized populations at the center of action.”); Wiley, supra note 20, at 101 (“[T]he health justice framework [should] root ongoing efforts to ensure access to health care and healthy living conditions more firmly in community engagement and participatory parity.”).
23 See Emily A. Benfer, Health Justice: A Framework (and Call to Action) for the Elimination of Health Inequity and Social Justice, 65 AM. UNIV. L. REV 275, 336–38 (2015).
24 We use the term “vulnerable communities” as a way to standardize the discussion about these communities, particularly as the term pertains to the vaccine distribution, which uses the social vulernability index (SVI) and the COVID-19 community vunerablity index (CCVI).

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pandemics has failed to address, and sometimes even exacerbated, inequities for many vulnerable communities.25 Building on the work of public health researchers, sociologists, legal scholars, and our prior work,26 we examine how the interplay of systemic racism, the governmental pandemic response, and unequal access to resources have resulted in racial inequities in COVID19 infections and deaths. We argue that these problems can be fixed by integrating the health justice framework, an emerging concept, into the federal and state government’s pandemic response.27
This Essay proceeds as follows: Part I discusses two forms of systemic racism (structural and interpersonal), how they negatively influence the federal and state government’s pandemic response, and the principles of the health justice framework that should be used to eradicate systemic racism in the government’s pandemic response. Using meat and poultry processing workers as an example, Part II demonstrates how systemic racism in the government’s pandemic response has caused and exacerbated employment inequalities. It concludes with suggestions for integrating the health justice framework into the government’s pandemic response, such as requiring employee safety boards in all essential businesses. Part III explores examples of systemic racism in health care and how they manifested themselves in this pandemic. After providing an overview of the challenges in health care that were laid bare in this pandemic, we suggest changes in income

25 Nina A. Kohn, The Pandemic Exposed a Painful Truth: America Doesn’t Care About Old People, WASH. POST (May 8, 2020, 8:49 AM), https://www.washingtonpost.com/outlook/nursing-home-coronavirus-discriminationelderly-deaths/2020/05/07/751fc464-8fb7-11ea-9e23-6914ee410a5f_story.html; T. Joanne Kene, Rachel Roubein & Susannah Luthi, How Public Health Failed Nursing Homes, POLITICO (Apr. 6, 2020, 4:30 AM), https://www.politico.com/news/2020/04/06/publichealth-failed-nursing-homes-167372; Teresa Ghilarducci, Covid-19 Makes Racial and Class Status Longevity Gaps Worse, FORBES (Mar. 2021, 7:43 PM), https://www.forbes.com/sites/teresaghilarducci/2021/03/21/covid-19-makes-racial-andclass-status-longevity-gaps-worse/?sh=207f2b21615d; The Marshall Project, A State-byState Look at Coronavirus in Prisons, MARSHALL PROJECT (Mar. 26, 2021 6:00 PM), https://www.themarshallproject.org/2020/05/01/a-state-by-state-look-at-coronavirus-inprisons; Phillip Sloane, Ruqaiijah Yearby, R. Tamara Konetzka, Yue Li, Robert Espinoza, & Sheryl Zimmerman, Addressing Systemic Racism in Nursing Homes: A Time for Action, 22 JAMDA 886-892 (2021).
26 See supra note 8. 27 Emily A. Benfer, Seema Mohapatra, Lindsay F. Wiley & Ruqaiijah Yearby, Health Justice Strategies to Combat the Pandemic: Eliminating Discrimination, Poverty, and Health Inequities During and After COVID-19, 19 YALE J. HEALTH POL’Y, L. & ETHICS 122, 136–41 (2020); Benfer, supra note 23, at 336–38; Wiley, supra note 20, at 47; Ruqaiijah Yearby & Seema Mohapatra, Structural Discrimination In COVID-19 Workplace Protections, HEALTH AFFS. BLOG (May 29, 2020), https://www.healthaffairs.org/do/10.1377/hblog20200522.280105/full/ [hereafter Yearby & Mohapatra, Structural Discrimination].

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supplementation, universal health care coverage, medical educational incentives, and community involvement in decision making.

I. COVID-19, SYSTEMIC RACISM, AND HEALTH JUSTICE Many low-income communities and low-wage workers—as well as racial and ethnic minorities—have been impacted disproportionately by COVID19. In fact, there is some overlap between class and race in inequalities in employment and health care that are associated with inequities in COVID-19 infections and deaths, particularly among essential workers. However, the ways that racial and ethnic minorities have been treated and blamed for inequities in COVID-19 is different than how low-income communities and most low-wage workers have been treated. For example, some federal public health officials and state government officials have begun to blame minorities for racial inequities in COVID-19.28 After lifting mask mandates and other COVID-19 restrictions in March 2021, Texas Governor Greg Abott blamed an increase in COVID-19 infections on undocumented immigrants from Mexico, without any supporting proof.29 In June 2020, Ohio State Senator and physician, Stephen A. Huffman, who was charged with enacting laws to protect citizens from the spread of COVID-19 and treating COVID-19 patients, speculated “could it just be that African-Americans or the colored population do not wash their hands as well as other groups or wear a mask or do not socially distance themselves?”30 In January 2021, he was appointed the chair of the Ohio Senate Health Committee by his cousin, Senate President Matt Huffman.31

28 See Carmen Sesin, Latino Leaders Demand Florida Governor Apologize for Linking ‘Hispanic Farmworkers’ to COVID-19 Rise, NBCNEWS (June 22, 2020, 6:23 PM), https://www.nbcnews.com/news/latino/latino-leaders-demand-gov-desantis-apologizelinking-hispanic-farmworkers-covid-n1231785; Brett Murphy & Letitia Stein, Feds Explore Whether Latino Immigrants to Blame for Coronavirus Flare-ups, USA TODAY (Jan. 26, 2021, 6:05 PM), https://www.usatoday.com/story/news/investigations/2020/06/18/coronavirus-flare-upsraise-task-force-questions-immigration/3210219001/; Trip Gabriel, Ohio Lawmaker Asks Racist Question About Black People and Hand-Washing, N.Y. TIMES (June 11, 2020), https://www.nytimes.com/2020/06/11/us/politics/steve-huffman-african-americanscoronavirus.html; Sarah Westwood & Sunlen Serfaty, HHS Secretary Tells Lawmakers Lifestyles of Meat-Processing Plant Employees Worsened Covid-19 Outbreak, CNN (May 7, 2020, 4:58 PM), https://www.cnn.com/2020/05/07/politics/alex-azar-meat-processingplants/index.html. Where relevant we have included a discussion of low-income communities.
29 Noah Higgins-Dunn, Texas Gov. Abbott Blames Covid Spread on Immigrants, Criticizes Biden’s ‘Neanderthal’ Comment, CNBC (Mar. 4, 2021, 11:42AM EST), https://www.cnbc.com/2021/03/04/texas-gov-abbott-blames-covid-spread-on-immigrantscriticizes-bidens-neanderthal-comment-.html.
30 Gabriel, supra note 28. 31 Farnoush Amiri, Legislator Who Questioned Black Hygiene to Lead Health Panel,

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RacismInequitiesMinoritiesHealth CareLaw