Court Confirms New York’s Elimination of Religious Exemptions for School Vaccination Mandates

On March 3, a federal appeals court threw out a challenge from Amish groups regarding New York state’s decision to eliminate religious exemptions for school vaccination requirements.

The U.S. Court of Appeals for the Second Circuit determined that the Amish plaintiffs failed to demonstrate any violations of their constitutional rights.

The three-judge panel included U.S. Circuit Judges Jose Cabranes, Eunice Lee, and Richard Wesley.

For many years, New York permitted religious exemptions for vaccinations against illnesses such as measles, polio, and pertussis.

In 2019, state lawmakers passed an amendment to the public health law following a measles outbreak attributed, in part, to unvaccinated children. This amendment eliminated the option for a religious exemption, leaving only a medical exemption available with a doctor’s certification that a vaccination “may pose a risk to a child’s health.”

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In 2023, Amish parents and schools filed a lawsuit against New York, claiming that the removal of the religious exemption breached their constitutional rights, including the First Amendment right to free expression.

“Although the Plaintiffs’ claims appeared to be valid initially, the Court is obligated to adhere to the Second Circuit’s recent ruling,” Wolford remarked.

In their appeal, the Amish asserted that the law was driven by discrimination, citing comments made by certain lawmakers.

The Second Circuit judges disagreed with this assessment.

They indicated that, while a few legislators may have made such remarks, the Amish did not provide evidence that a significant number of legislators shared those opinions. Conversely, many lawmakers expressed support for religious freedom, and approximately 40 percent of both legislative chambers voted against the repeal.

The judges also dismissed the contention that the medical exemption in the vaccination law implies that secular actions are favored over religious beliefs. They clarified that the medical exemption is more limited as it necessitates a doctor’s assessment that a specific vaccine might be harmful to a child’s health and must be renewed annually. In contrast, the religious exemption previously covered a child’s entire duration in school and extended to all essential vaccinations.

“The reach of the religious exemption had a far greater potential to undermine the State’s interest in curbing disease outbreaks,” they concluded.