Holy Exemption or Health Risk? The Legal Battle Over College Vaccine Mandates

In 2021, Western Michigan University (WMU) introduced a COVID-19 vaccine mandate requiring all student-athletes to be vaccinated to participate in sports. Several student-athletes opposed the requirement for religious reasons and requested exemptions. They argued that getting the vaccine conflicted with their faith. WMU denied all religious exemption requests but allowed medical and other non-religious exemptions. As a result, the affected athletes sued, arguing that the policy violated their First Amendment right to religious freedom. Dahl v. The Board of Trustees of Western Michigan University raised important legal questions about whether public universities can enforce vaccine mandates in a way that treats religious beliefs differently from other exemptions.

The main issue in this case is whether Western Michigan University (WMU) violated the First Amendment’s Free Exercise Clause by allowing medical exemptions to its COVID-19 vaccine mandate but denying religious exemptions. This clause protects people from government actions that unfairly target or burden religious beliefs. Employment Division v. Smith (1990) helps explain this issue. In Smith, the Supreme Court ruled that if a law is neutral and applies equally to everyone, meaning it does not specifically target religion, it does not violate the Free Exercise Clause of the First Amendment, even if the law happens to burden religious practices indirectly. Applying this to WMU’s vaccine mandate, the key question is whether the university’s policy is neutral. WMU allowed medical exemptions but denied religious ones, raising concerns that the policy may not be applied equally. This could be seen as discriminatory if the university reviewed medical exemption requests individually but automatically rejected religious exemptions. The Smith ruling suggests that WMU could potentially defend its vaccine mandate by arguing that it is a neutral, generally applicable rule. The case ultimately asks whether WMU’s policy meets the standard of being neutral or if it unfairly singles out religious exemptions.

This case has broader implications that go beyond just Western Michigan University. It brings attention to the ongoing tension between the government’s role in protecting public health and individuals’ right to practice their religion freely, as guaranteed by the First Amendment. The case raises important questions about whether public institutions can deny religious exemptions to health policies like the COVID-19 vaccine mandate while allowing medical exemptions. This could set a dangerous precedent for limiting religious freedoms under the mask that it is for public safety. If the court sides with WMU, it would give more power to institutions to enforce health policies. However, if the student-athletes win, it could limit how institutions can enforce vaccine requirements in the future. This could potentially lead to legal challenges for other policies that deny religious exemptions. This would affect vaccine mandates and other public health policies, such as mask mandates or future health regulations. 

There are two sides to this case, one focused on religious freedom and the other on public health. From a pro-religious freedom view, WMU’s policy appears biased because it allowed medical exemptions but denied religious ones. This lack of neutrality could be seen as unfair treatment of religious beliefs. Since WMU allows medical exemptions but denies religious ones, this could be considered unconstitutional discrimination against religious freedom. On the other hand, from a pro-public health view, universities should have the authority to impose reasonable health mandates. This is for the “common good” of the students and staff to protect their health. Public health is a priority, and universities must ensure their campus is safe from outbreaks. Granting too many religious exemptions could weaken the effectiveness of vaccine policies and potentially lead to more infections, making it harder to control the spread of COVID-19 on campus. Medical exemptions are also different because they are based on a person's physical inability to get the vaccine due to health problems. Religious exemptions are personal and can not be proven sincere, which creates a dangerous slippery slope that could lead to a situation where people might claim religious beliefs as a way to avoid the vaccine. This creates a challenge in enforcing vaccine mandates fairly.

In regard to the constitutional issue, I agree with the university's stance that religious exemptions should not be granted in this case because public health is more important for the common good. While the First Amendment protects individuals' right to religious freedom, in situations like a public health crisis, protecting the health and safety of the community should take precedence. The vaccine mandate is not about targeting religious beliefs but about ensuring the well-being of everyone on campus. Regarding public health, specific measures like vaccine mandates are necessary to protect the greater good, even if they may indirectly burden individual freedoms in particular situations.

Sources:

https://law.justia.com/cases/federal/appellate-courts/ca6/21-2945/21-2945-2021-10-07.html

https://www.greatlakesjc.org/cases/dahl_v_wmu/ 

https://reason.com/volokh/2021/10/07/victory-for-wmu-student-athletes-with-religious-objections-to-vaccination/