Miller v. McDonald

Overview

(2d Cir., March 3, 2025): The Second Circuit Court of Appeals upheld New York’s repeal of its religious belief exemption for school immunizations, holding the State did not violate 1st Amendment rights of Amish parents or schools. The court applied rational basis review after concluding the law is neutral on its face. The State repealed its religious belief exemption in 2019 following a severe measles outbreak where most cases occurred in communities that contained schools with insufficient immunization rates. The court rejected comparisons to the 1972 Supreme Court case, Yoder, which held that the right to free exercise of religion outweighed the state’s interest in compulsory education for children. Read the full opinion here.

View all cases in the Judicial Trends in Public Health – May 20, 2025.

View all cases under “Preventing and Treating Communicable Conditions.”