“They are very egregious,” said Dorit Reiss, a professor at UC Law San Francisco who studies vaccine law and policy.
The group's founder and director is William Lionberger, a chiropractor licensed to practice in California since 1981 and who once had a practice north of San Diego. He also served as a police officer in a city near Sedona, according to public records. (Lionberger declined a request for an official interview, and the organization did not answer a list of questions from Undark.) Interviewers who have hosted Lionberger on their shows describe him as affiliated with America's Frontline Doctors, a group that has opposed Covid-19 vaccines and other public health measures while promoting unproven treatments like hydroxychloroquine.
The Frontline Health Advocates webpage was first registered in March 2022, with a name similar to America's Frontline Doctors. In April of that year, the website invited visitors to “get your waiver now.” In a 2023 interview, Lionberger described having a “team of medical experts” who “work with all kinds of situations” and evaluated clients for both “regular vax injuries and regular vax exempt conditions.”
He added: “People now don't even want their children to get anywhere near a regular vaccine.”
The group uses a few distinctive legal strategies. One is to form itself as something called a Private Ministerial Association. Online, some groups that help form such private associations describe them as offering special First Amendment protections. A membership application document hosted on Frontline's website describes the group as “a private, unincorporated ministry that operates, to the maximum extent possible, outside the jurisdiction of government agencies, agencies, officers, agents, contractors and other representatives, as protected by law.”
Another strategy is to rely on federal disability law. In the 2023 interview, Lionberger boasted that they used “the most powerful thing you can bring against discrimination” — specifically federal protections. A promotional video posted on the Frontline website makes a similar claim, calling advertising exemptions “backed by protections under U.S. federal law.” Undark received three nearly identical waivers in 2024 that were sent to families in New York. In it, Frontline states that the client's need for a medical exemption is protected under the Americans with Disabilities Act, or ADA, which guarantees certain accommodations for people with disabilities and other medical needs.
