A federal court last week ruled against a group of Amish parents who sought religious exemptions from school vaccination requirements for their children — a ruling that legal experts suggest may lead to a U.S. Supreme Court showdown that could determine the future of religious exemptions nationwide.
In its ruling in Miller v. McDonald, the 2nd U.S. Circuit Court of Appeals said New York State’s law eliminating religious exemptions from school vaccination requirements is “neutral and generally applicable,” doesn’t discriminate against specific religious practices and furthers the state’s interest in protecting the public from disease.
The plaintiffs, a group of parents and representatives of Amish schools in New York, sued New York’s Department of Health and Department of Education in 2023, alleging the state’s law barring religious exemptions violates the U.S. Constitution’s Free Exercise Clause under the First and 14th Amendments.
The parents face $118,000 in fines for noncompliance with the state’s vaccination requirements.
Last week’s decision was the second time the 2nd Circuit ruled against the plaintiffs. The same court previously dismissed the suit in 2024, upholding a decision by another federal court earlier that year.
In December 2025, the Supreme Court sent the case back to the 2nd Circuit, asking it to review constitutional questions arising out of a separate ruling, Mahmoud v. Taylor, in 2024. In that case, the Supreme Court found that parents have the right to request an exemption for their children from LGBTQ curriculum on religious grounds.
According to The Washington Post, last week’s ruling in Miller v. McDonald may “set the stage for a potential Supreme Court battle over vaccine mandates,” citing legal experts who suggested the court is likely to accept the case for review on constitutional grounds and in light of the Mahmoud v. Taylor decision.
Lawrence Gostin, a Georgetown University professor of health law and an outspoken vaccine proponent, told the Post he expects the Supreme Court to “reverse the appellate court’s decision” if it chooses to review the case.
A review could result in a ruling that would “allow religious vaccine exemptions nationwide,” the Post reported.
The Post reported last month that the Supreme Court has signaled that it “may be open to a constitutional claim based on the lack of a religious exemption for vaccine mandates in New York.”
A Supreme Court ruling in favor of the Amish plaintiffs would be “the anti-vaccine movement’s biggest win,” the Post wrote.
Hellbound and Down 