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Judicial Trends in Public HealthPreventing and Treating Communicable Conditions

We The Patriots USA v. Connecticut Office of Early Childhood Development


(U.S. Court of Appeals for the 2nd Circuit, August 4, 2023) The Second Circuit Court of Appeals found that amendments to Connecticut’s vaccination law removing the religious exemption were constitutional, but remanded the case to consider whether the amendments violate the Individuals with Disabilities in Education Act (IDEA). Connecticut’s vaccination requirements for children enrolled in public and nonpublic schools or attending childcare centers and group childcare homes, and for students enrolled in public and private institutions of higher education, were changed such that religious exemptions to vaccination would no longer be permitted. Medical exemptions remain. Parents and an advocacy organization argued that the amendments violated the Free Exercise Clause, due process rights to privacy and medical freedom, equal protection, and liberty interests in childrearing. One parent alleged that the amendments violated the IDEA. The Court found that the amendments and related legislative history “contain no trace of hostility toward religion but rather reflect significant accommodations on the part of the legislature.” The Court affirmed dismissal of the substantive due process claims because there is no fundamental right to an education or to avoid vaccination and the law does not compel vaccination. The Equal Protection claim of age-based classification was dismissed because the classification was rationally related to Connecticut’s interest in protecting the health and safety of students. The IDEA claim may proceed. Read the full Opinion here.

View all cases in the Judicial Trends in Public Health – November 20, 2023.

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