The U.S. Supreme Court ordered a federal appeals court to reconsider its decision to uphold a New York state law that denies a group of Amish parents religious exemptions to state-required school vaccinations. In 2019, New York removed the long-standing practice of allowing religious exemptions to public school-mandated vaccines after a severe measles outbreak. In Miller v. McDonald, three Amish private schools have been financially sanctioned for allowing children to attend school without being vaccinated. Joined by Amish parents, the lawsuit challenges New York under the First Amendment’s free exercise of religion claiming the law categorically denies religious exemptions while allowing medical exemptions.
According to Monday’s order list, the Supreme Court granted the petition, vacated the judgment of the U.S. Second Circuit Court of Appeals, and remanded it back down with instructions to review the case again in light of the parental rights case Mahmoud v. Taylor.
In June 2025, SCOTUS sided with Maryland parents in Mahmoud upholding their right to opt their children out of LGBTQ-themed curriculum that went against their religious convictions. The Mahmoud decision not only emphasized that parents could challenge government policies when they interfere with religion, but it also upheld that parents do not surrender their religious free exercise right to direct the upbringing of their children who attend public schools.
The implications of the High Court directing another review of Miller under the Mahmouddecision signals that the application of First Amendment parental control rights can extend more broadly beyond education into vaccine mandates when they collide with religious beliefs.
In writing the Mahmoud majority opinion, Justice Samuel Alito relied heavily on another Amish case in Yoder v. Wisconsin where the High Court restricted the boundary between state schooling requirements and religious freedom. In 1972, Wisconsin tried to force the Amish community to send its children to high school even though the Amish elect to finish formal education at eighth grade and proceed with hands-on vocational and religious life training. The High Court sided with the Amish finding that forcing their children to attend high school would substantially burden their religious practice without a compelling reason to do so.
In Mahmoud, Justice Alito repeatedly cited Yoder as a principle for “robust protection of religious liberty” where parents have a constitutional right “to direct the religious upbringing of their children.” He added that laws infringing this right pose “a very real threat of undermining” religious beliefs and practices and emphasized that parental rights are not confined to the home but follow children into the public square.
The Court concluded in Yoder, wrote Justice Alito, that a law which “substantially” interferes “with the religious development of the Amish child” carries an “objective danger” to religion “that the First Amendment was designed to prevent.”
The First Amendment forbids compelling children to depart from the religious practices of their parents, concluded Justice Alito.
Liberty Counsel Founder and Chairman Mat Staver said, “The U.S. Supreme Court’s decision to send Miller v. McDonald back for reconsideration under Mahmoud v. Taylorshows that the principles of parental religious rights in that case extend beyond public school LGBTQ indoctrination into other matters of faith involving free exercise of religion. Parental rights and the free exercise of religion do not vanish simply because the context changes. The First Amendment protects the space where families live out their convictions and make choices for their children without unnecessary government interference that violates their faith.”
