A group of Amish parents and schools in New York lost their second bid to secure a religious exemption to state vaccine mandates in June after the U.S. Supreme Court sent the case back to an appeals court for reconsideration.
Bloomberg Law reported the U.S. Court of Appeals for the Second Circuit had previously affirmed a lower court’s 2024 decision to dismiss allegations that New York violated three private Amish schools’ First and 14th Amendment freedoms.
In their review, the Second Circuit’s three judges refused to revive the schools’ religious exemption, stating the vaccine mandate is neutral and supports New York’s rational interest in curbing the spread of contagious diseases without targeting or prohibiting religious practices.
New York decided to no longer allow religious exemptions to school vaccination requirements in 2019 following a measles outbreak at an Orthodox Jewish school.
Joseph Miller, Ezra Wengerd and Jonas Smucker filed a lawsuit against New York’s commissioners of health and education claiming requirements for measles, polio, chicken pox and whooping cough vaccinations violated their religious freedom. The state’s health department imposed penalties of $2,000 per violation against Dygert Road School, Pleasant View School and Shady Lane School.
The Amish challenge cited the 1972 Supreme Court Wisconsin v. Yoder decision, which exempted Amish from compulsory education past eighth grade, and claimed the Amish commitment to living separately from the modern world includes vaccines.
The Supreme Court sent the case back to the Second Court after ruling in a separate case that a Maryland school district violated parents’ constitutional rights when it used LGBTQ-inclusive books without informing parents.

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