Miller v. McDonald

In Miller v. McDonald, the U.S. Court of Appeals for the Second Circuit denied a religious right to the Amish from mandatory vaccination. The background was this:

“

... the legislature repealed the religious beliefs exemption while retaining the medical exemption. Plaintiffs-Appellants are three "Amish community schools"—Dygert Road School, Pleasant View School a/k/a Twin Mountain School, and Shady Lane School—that have been fined for failing to comply with New York's immunization law; Ezra Wengerd, an elected representative of all Amish schools in New York; and Jonas Smucker and Joe Miller, board members of their children's Amish community schools (collectively, "Plaintiffs"). The schools do not require a certificate of immunization to attend because the parents "have sincerely held religious beliefs which do not permit them to inject" their children with vaccines.

”

Miller v. McDonald, 130 F.4th 258, 262 (2d Cir. 2025).

The Second Circuit then held:

“

Plaintiffs brought a claim pursuant to 42 U.S.C. § 1983 against Defendant-Appellee Dr. James V. McDonald, in his official capacity as the Commissioner of Health of the State of New York ("the State"), alleging that the immunization law infringes on their free exercise rights under the First and Fourteenth Amendments. The parents also argue that the law is unconstitutional because it impairs Amish parents' right to control the religious upbringing of their children as recognized in Wisconsin v. Yoder, 406 U.S. 205, 92 S. Ct. 1526, 32 L. Ed. 2d 15 (1972). Plaintiffs moved to preliminarily enjoin the law's enforcement against them; the State moved to dismiss. Chief Judge Elizabeth A. Wolford granted the State's motion to dismiss, concluding that Plaintiffs failed to plausibly allege a constitutional violation. The court denied Plaintiffs' request for a preliminary injunction as moot. We affirm.

”

Miller v. McDonald, 130 F.4th 258, 262 (2d Cir. 2025).