of care, in some cases, treatment may also constitute a crime, such as battery. (39) Criminal battery stemming from violations of medical ethics and informed consent standards have led to a significant degree of distrust of the government, public health officials, and medical professionals by certain groups and communities including among the most vulnerable populations such as ethnic minorities, immigrants, economically disadvantaged, unmarried mothers, people with disabilities, and individuals with mental illnesses. (40) On March 19, 2021, the WHO released draft recommendations for a smart vaccine certificate in what amounts to a form of a vaccine passport that would, per WHO’s Smart Vaccination Certificate Working Group , support COVID–19 vaccine delivery and monitoring and to serve current and future requirements, toward the dual purposes of (1) supporting continuity of care