German Law Journal 1659 tools to resist the inevitability that those who have suffered most from the pandemic should also “pay” for it through austerity, as happened after the financial crisis of 2008 onwards. That these communities have indeed paid can be demonstrated by the calculations of researchers who have estimated that there have been tens of thousands of preventable deaths from austerity just in the UK.162 One further advantage of a citizenship rather than human rights framing for future-focused arguments about protecting the vulnerable is that it fosters a focus on obligations as well as rights. In other words, a revived and potentially constitutionalized conception of social citizenship can be used to justify restrictions on individual freedoms in the collective interest but in such a way that pays special attention to the vulnerable. For example, a mask mandate may seem to be a straightforward way of reducing risk, especially indoors.163 Yet certain groups, such as those with hearing difficulties or asthma, or others who have faced previous trauma around suffocation, may find themselves marginalized by a mask mandate applied without regard to their specific interests. Designing sensitive policies needs to engage policymakers and other stakeholders. Courts cannot be the primary actors as there would be limits to the extent that they could effectively intervene in areas requiring complex policy solutions, except to prevent egregious interferences with individual freedoms or to protect specific groups whose interests have been left out of the policy-making process. That said, there have already been examples where courts have engaged constructively in the contestation of similar political choices, for example, in a federal context in Brazil.164 An obligations approach can also be supplemented by a principle of gratitude, which can be seen in some countries that have taken steps to give permanent residence to frontline workers in precarious situations.165 As an emotion, gratitude has been brought to the fore, as shown by examples such as “clap for carers” and other measures taken in the UK and elsewhere to express thanks to those who have taken on an outsize level of risk during the pandemic. This was especially salient at the outset of the pandemic, when the risks were not well understood and there was a shortage of personal protective equipment. But, later on, emotions have spilled over into anger at the failure of public authorities to translate gratitude into concrete steps to reward at-risk groups.166 One sign of a broken social contract is a requirement that workers isolate themselves if they have tested positive or come into contact with someone who has tested positive, and yet they are not provided comprehensive sick pay coverage to prevent personal financial loss. Across the world, the pandemic has reworked concepts of risk and skill such that it could be conceivable to develop new frames of deservingness that do not replicate the pitfalls of current approaches and that can decrease rather than increase the effects of marginalization.167 These are the raw materials on the basis of which societies can truly “build back better.” H. Conclusions This article has begun the task of outlining the impacts of the pandemic in matters of citizenship using a syndemic analysis placing both the pandemic and the ideas and practices of citizenship in their wider contexts. It sets the scene for more detailed research in the future. While the scope of 162 Dean Hochlaf, Harry Quilter-Pinner & Tom Kibasi, Ending the Blame Game: The Case for a New Approach to Public Health and Prevention, IPPR (Jun. 4, 2019), https://www.ippr.org/files/2019-06/public-health-and-prevention-june19.pdf. 163 Trisha Greenhalgh, Face Coverings for the Public: Laying Straw Men to Rest, 26 J. EVALUATION CLINICAL PRAC. 1070 (2020). 164 João Biehl, Lucas E.A. Prates & Joseph J. Amon, Supreme Court v. Necropolitics: The Chaotic Judicialization of COVID-19 in Brazil, 23 HEALTH & HUM. RTS. J. 151 (2021). 165 Mollie Gerver, The Case for Permanent Residency for Frontline Workers, AM. POL. SCI. REV. (2021). 166 Helen Wood & Beverley Skeggs, Clap for Carers? From Care Gratitude to Care Justice, 23(4) EUR. J. CULTURAL STUD. 641 (2020). 167 Maike Isaac & Jennifer Elrick, How COVID-19 May Alleviate the Multiple Marginalization of Racialized Migrant Workers, 44 ETHNIC & RACIAL STUD. 851 (2021). https://doi.org/10.1017/glj.2021.77 Published online by Cambridge University Press