include invocations, before school board meetings did not violate the Establishment Clause of the First Amendment, under the Supreme Court's legislative prayer exception. Abortion In 2018, Smith wrote the majority opinion in June Medical Services v. Gee, 905 F.3d 787 (5th Cir. 2018), which held that the Louisiana Unsafe Abortion Protection Act (Act 620), which required doctors performing abortions to be admitted at nearby hospitals, was constitutional. In 2020, the decision was reversed in a 5–4 decision by the U.S. Supreme Court in June Medical Services, LLC v. Russo. Qualified immunity In 2019, Smith wrote the majority opinion in Taylor v. Williams, 715 F App'x 332 (5th Cir. 2017). Smith granted qualified immunity to correctional officers for their treatment of a prisoner subjected to six days' seclusion in cells covered in feces, with no water or toilet available, because it "wasn't clearly established" that "prisoners...housed in cells teeming with human waste [for] a time period so short violated the Constitution," holding that the illegality of such actions was not "beyond debatable." 2020 election On January 2, 2021, Smith, along with Patrick E. Higginbotham and Andy Oldham, affirmed the dismissal for lack of jurisdiction of a lawsuit filed by Louie Gohmert aimed at empowering Vice President Mike Pence to overturn President-Elect Joseph Biden's Electoral College win. Vaccine mandates On February 9, 2022, Smith was one of two judges who declined to rule on a request to stay a preliminary injunction against Biden's COVID-19 vaccine mandate for federal employees. Judge Stephen A. Higginson dissented from that ruling, arguing that the government was entitled to an immediate stay while it appealed. On February 17, Smith dissented when the majority, Jennifer Walker Elrod and Andy Oldham, reversed the district court's order denying a preliminary injunction to employees challenging United Airlines' vaccine mandate. Smith's dissent of nearly 60 pages accused the majority of flouting "fifty years of precedent and centuries of Anglo-American remedies law" and ignoring the text of the relevant statute "to extract its desired result.". He also criticized the majority for hiding its "made-up" legal theory in an unsigned and unpublished opinion. "If I ever wrote an opinion authorizing preliminary injunctive relief for plaintiffs without a cause of action, without a likelihood of success on the merits (for two reasons), and devoid of irreparable injury, despite the text, policy, and history of the relevant statute, despite the balance of equities and the public