As early as 1830, the Amish began settling in New York. They came to the United States in search of religious liberty. The Amish have been good citizens, and New York has accommodated their faith. The Amish community has a religious objection to vaccinations. For over 50 years, New York State has exempted them from attending their private Amish schools and to tend to their health as their faith permits. In 2019, New York repealed this exemption, following a major measles outbreak. Some New York legislators described religious objections to vaccinations as “fake” and “garbage,” and even called their beliefs “selfish and misguided.” Forty-five states and the District of Columbia continue to allow religious exemptions for school vaccine requirements, making New York an extreme outlier on the issue. The conflict between the Amish community and vaccination requirements is central to Miller v. McDonald, a case that raises important questions about religious freedom and public health. In this case, the main question that can be considered is: Can New York require Amish parents to vaccinate their children when doing so conflicts with their sincere religious beliefs and desire to raise their children in accordance with those beliefs, or does the Free Exercise Clause protect them from that requirement?
In this case, New York wants to impose penalties on three Old Order private Amish schools that exist on their private Amish farms, in small Amish communities that refuse to require vaccinations because it conflicts with their faith. The schools were fined a total of $118,000 for failing to agree with the vaccination requirements. Previously, the Supreme Court said parents have the constitutional right to guide and decide their children's religious upbringing. In Wisconsin v. Yoder, the Court affirmed this right. In this case, the law “Public Health Law 21664” is repeatedly referenced because it requires parents to vaccinate their children even if they have sincere religious beliefs against vaccination. The parents argue that vaccination is especially serious in their faith, as it is permanent and can not be undone. The law interferes with parents' ability to raise their children in accordance with their religious beliefs.
The Central Constitutional question is whether New York can require the Amish parents to choose between following their religious beliefs and sending their children to Amish schools. In Wisconsin v. Yoder, Jonas Yoder refused to send his 15- and 14-year-old children to school after eighth grade because he believed that high school exposed his children to values and lifestyles that directly contradicted his fundamental religious beliefs. The Supreme Court recognized his right to direct his children's religious upbringing and held that requiring him to send his children to high school violated the Free Exercise Clause and outweighed the state's interest in making attendance mandatory. In the case, Miller .v. McDonald, they argue that New York’s law substantially interferes with their ability to raise children according to their faith, as vaccination is permanent and irreversible, and contradicts the values and beliefs that they are trying to teach their children. The petitioners argue that New York’s law forces an unjust burden on the Amish religious exercise, forcing them to commit this irreversible act and forcing them to do so would contradict the ruling of the Yoder case.
The Second Circuit Court disagreed, and it held that New York’s vaccination law was neutral toward religion and applied generally; the court also concluded that the law did not create the same type of burden involved in Yoder. The Second Circuit argued that this vaccination requirement does not interfere with Amish education in the same way Yoder interfered with their religious upbringing. I agree with the court on this point, as the New York court does not specifically target the Amish community and does not prohibit them from practicing their religion. The vaccine requirement applies broadly to students attending New York schools, particularly after a measles outbreak in 2019, giving them a strong reason to demand vaccination. However, I think the facts of this case still need to be considered. The New York Legislators described religious objections to vaccinations as “fake” and “garbage,” along with other hostile wording calling into question whether the government can enforce a law against religious conduct after the government has expressed hostility toward the religious beliefs. This is where Miller can be compared to Masterpiece Cakeshop v. Colorado Civil Rights Commission. In Masterpiece Cakeshop, the Supreme
Court ruled in favor of a Christian baker after the Colorado Civil Rights Commission made hostile comments about his religion. In this case, a homosexual couple requested a custom cake for their upcoming wedding reception, and the Christian baker refused, as he did not approve of same sex marriage. The Supreme Court ruled that the Colorado Civil Rights Commission violated the baker’s Free Exercise Clause. The court emphasized that the government cannot treat religious beliefs as illegitimate, focusing heavily on the conduct of the Colorado Commission directed at the baker. This is directly applicable to the Miller case: can free exercise be called into question because of the hostile words chosen by the New York Legislators?
I ultimately agree with the Second Circuit Court on their ruling; while medical exemptions do remain available for children who can not safely receive vaccinations, the state has a strong interest in getting involved, as it is a matter of public health. This case has interesting layers as it brings into question how the government's treatment and opinions should affect a free exercise claim. New York clearly has a serious, compelling state interest in public health, especially the requirement that children be vaccinated. However, the Amish are not simply disliking this law; it directly inhibits their ability to practice their religion and would directly burden them. I agree with the Second Circuit that a medical exemption addresses the safety of a child receiving a vaccination, while a religious objection is based on the beliefs of a family, not prioritizing the greater good of child safety. In my view, these comments from the New York legislators are serious, but they cannot automatically determine the case. The government’s concern for public health does not disappear just because of offensive comments or because a community rejects vaccinations due to their religion. In the end, the Second Circuit Court delivered a neutral and generally applicable vaccination requirement; although it imposes a burden on the Amish community, it must also consider the safety of the majority of children; exempting one group from vaccination could open the door for other groups to claim that they also can not receive a vaccination.
16 comments:
I agree with your argument that the state of New York should be allowed to implement vaccine mandates. In my opinion, there is little validity to the plaintiffs' argument that this case is similar to Yoder, as the compelling state interest of New York is far greater than that of Wisconsin in Yoder due to the recent measles outbreak. It is also important to emphasize the importance of the fact that the welfare of children is involved in this case. Children are much more susceptible to disease, making mandatory vaccines in schools a compelling interest of the state. That being said, I think New York legislators describing religious objections to vaccinations as "fake" and "garbage" is completely distasteful. The individual opinions of lawmakers has no place in reviewing constitutionality.
I agree with your statement that although the vaccine imposes a burden on the Amish community, we must also consider the safety of the majority of children and that exempting one group from vaccination could open the door for other groups to claim that they also can not receive a vaccination. When it comes to most religious practices or rituals, I believe religious groups should be free to follow their beliefs as long as their actions do not harm others. However, this situation is different because the decision not to vaccinate could affect the health and safety of other students, not just the Amish family making that decision.
I agree with your argument that New York's vaccination requirement is different from Yoder because refusing vaccinations can directly harm other people's health. However, the legislators' comments calling religious objections "fake" and "garbage" are concerning because the government should remain neutral towards any religious beliefs, as Masterpiece Cakeshop established. These comments could possibly suggest religious hostility towards a particular religion.
I agree with the author’s argument that the vaccination requirement should be upheld. I think the state has a compelling interest in protecting public health and safety, especially when it comes to preventing the spread of serious diseases among children. While religious freedom is important, I believe it should be balanced with the need to protect the health of the larger community. Requiring vaccinations helps protect not only the individual but also other students who may be more vulnerable to illness. Therefore, I think the state is justified in enforcing vaccination requirements for the safety of everyone.
I agree with the argument that the vaccination requirement should be upheld. Even though the schools are separate from everyday schools, the Amish community does not have full separation from the rest of society which could pose health risks to people not in the Amish community. I believe the law is neutral because it applies to all children unless there is a medical exemption. I do think that the legislator's comments about their objections are harmful, as these issues do stem from the beliefs of the Amish people and should not be treated disrespectfully just because they do not follow the same ideals that the legislators do.
I really liked the Masterpiece Cakeshop comparison, and I agree with you that the legislators' comments are bad but shouldn't decide the whole case on their own. The one thing I kept thinking about is that in Masterpiece the hostile comments came from the actual people ruling on the baker's case, while here it was just a few legislators talking about a law that applies to everybody, so I feel like that makes it a tougher argument for the Amish. I'm also curious what you think about the 45 other states that still allow religious exemptions, because to me that makes it a little harder for New York to say getting rid of theirs was the only way to keep kids safe.
I agree with your conclusion here that the Second Court's ruling was the correct decision. I think you made two very compelling points in support of this argument. The first was the distinction you made between what allowing the Amish to do this would further or help. I think it is important to look at the fact that the religious objection to this exemption are based on the beliefs of the family's values and religious beliefs, while the State's interest focuses soley on the greater good of child safety. The second argument you made was the fact that the deragatory and offensive language used by the officials do not invalidate the fact that the state's comeplling interest outweighs the religious burden imposed by requiring the vaccination. I think this is incredibly important as well, because while their language might suggest the officials were discriminating against their beliefs by doing this, the State itself still has a compelling interest behind the broader requirement, regardless of individual beliefs held by the officials. Furthermore, I think that the fact that New York accommodated their religious beliefs up until they had an outbreak that then caused the religious burden to be outweighed by the overall health and wellbeing of children. This demonstrates that the purpose behind the newfound requirment were based out of assumed necessity, not discrimination.
I really liked your comparison here to Masterpiece Cakeshop. I think even though the vaccine law does technically apply to everyone, I think lawmakers classifying religious beliefs as “fake” and “garbage” blurs the line of neutrality. How can you really say the courts were being entirely neutral here? At the same time, vaccines are different as one person’s choice can really affect the health of others. My final thought was, when do negative comments about religion start to turn a neutral law into a Free Exercise violation?
I disagree with your conclusion that the Old Order Amish community should be forced to vaccinate their children. As stated, New York State is an outlier across the nation to not have a religious exemption to vaccinations. Thus there is a least restrictive means that is more accommodating to the Old Order Amish communities free exercise rights as outlined in the First Amendment.
I agree with your argument that New York’s responsibility to protect public health supports the vaccination requirement. Allowing religious exemptions could affect children outside the Amish community, especially those who cannot safely receive vaccines. Your distinction between medical and religious exemptions strengthens this point because they serve different purposes. Although the legislators’ hostile comments deserve criticism, I agree that they should not automatically outweigh the state’s responsibility to protect children.
I liked your argument and found the comparison to Cakeshop very unique, however I disagree. I think there should be a narrow exemption for the Amish. Firstly, the irreversible nature of the vaccine shouldn’t be downplayed at all. In the eyes of the Amish this is a serious matter that puts tension between pursuing life in the eternal or the temporal. The state is putting the parents in an irreconcilable position where the parents are being mandated to vaccinate their children, which will, “conflict[-] with their sincere religious beliefs,” potentially harming their children’s eternal religious salvation in exchange for a vaccine for an illness they may not come into contact with. In addition, I think Yoder touches upon an important idea that the Amish are a functioning, isolated community; as said in this article, the schools where these children are attending are “private Amish schools that exist on their private Amish farms, in small Amish communities.” They are isolated and functioning in their own world. Yoder also highlights the long and rich history of the Amish being given their own space and making their own decisions. I think if they so choose, they can determine what direction their community goes and how they want to apply their own beliefs to living. I think ruling in favor of forcing vaccines upon Amish children, and removing the decision from the parents, also could set a dangerous precedent that the government can start to interfere with the functioning of a historically independent religious group. Finally, I think that the court should rule narrowly in favor of the Amish, and just answer the Amish question here so as to limit/avoid unintended consequences. This is just a question about the Amish.
I agree with your argument that the vaccination requirement should be upheld however the comments that were made were not good. By calling someones religious beliefs are "fake" or "garbage" is not neutral from the government towards the religion. I think if other states allow religious exemptions then there should be no problem with other states doing so as well.
I agree with your argument that New York should not be required to allow this exemption for individuals in the Amish community. I think that the compelling state interest seen here with the recent measles outbreak, and potentially how severe the outbreak could become provide a strong enough reason for the state to override the Amish religious preferences. Additionally, this is not something that would only affect individuals within the Amish community, instead allowing this exemption could negatively impact anyone who the disease could spread to which includes secular individuals and individuals of other religions.
I definitely agree with your argument that New York should be allowed to require vaccinations in schools. It is necessary to mandate vaccines because without them we would all be sick with illness all the time. I also think protecting the health and safety of students is very important, especially after a measles outbreak. While religious freedom should be respected, I believe the state has a responsibility to protect everyone and prevent diseases from spreading.
I agree with you because I think New York has a strong enough reason to require vaccinations when it comes to public health and safety. I understand that the Amish families have sincere religious beliefs and that the requirement puts a burden on their religion. However, I think protecting the health and safety of children and preventing the spread of diseases is a compelling state interest. Especially since the law applies to everyone and is not specifically targeting the Amish community, I think it is neutral. I also think that allowing religious exemptions could affect more than just the families choosing not to vaccinate because it could put other children at risk.
I agree with your point that public health needs to be considered even when it goes against someone's religious beliefs. I thought your connection to Masterpiece Cakeshop was interesting because the comments make by New York Legislators could raise questions about religious discrimination. Would the court have viewed the case differently if there hadn't been a measles outbreak in 2019?
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