Federal Court Again Upholds New York’s Ban on Religious Exemptions From School Vaccine Requirements

A federal appeals court has again upheld New York’s elimination of religious exemptions from school vaccination requirements, rejecting claims that the law violates Amish families’ First Amendment rights.

Editorial Note

This article is provided for general educational and informational purposes and does not constitute legal, medical or public-health advice. It is based on publicly available court records, state-law information and reporting current as of the publication date.

The ruling discussed below was issued by the United States Court of Appeals for the Second Circuit on June 30, 2026. The New York State School Boards Association published an analysis of the decision on July 20. The court did not create a new vaccination requirement; it upheld New York’s existing law after reconsidering an earlier decision at the direction of the U.S. Supreme Court.

New To Education is not affiliated with the parties, their attorneys, the courts or any organization mentioned in this article. Families seeking guidance about vaccination, medical exemptions, religious rights or school enrollment should consult qualified healthcare and legal professionals.

New York’s prohibition on religious exemptions from school vaccination requirements has survived another major constitutional challenge.

In Miller v. McDonald, the Second Circuit again upheld the state’s immunization law after Amish parents and community schools argued that requiring vaccination as a condition of in-person school attendance violated their religious freedom and parental rights.

The court had previously ruled against the plaintiffs. The U.S. Supreme Court later vacated that judgment and directed the Second Circuit to reconsider the case in light of a more recent religious-liberty decision involving parents who objected to classroom materials.

After reviewing the dispute again, the appeals court reached the same conclusion. It ruled that New York’s vaccination requirement is a health-and-safety condition on school attendance—not an attempt to control what children are taught or interfere directly with their religious upbringing.

The decision leaves New York’s current system intact. Students attending public, private or parochial schools generally must satisfy the state’s immunization requirements unless they qualify for a medical exemption.

What New York’s Law Requires

New York Public Health Law Section 2164 requires children attending public, private or parochial schools for more than 14 days to be immunized against specified diseases.

For decades, the state permitted two primary exemptions. A child could be excused when a licensed physician determined that vaccination would be medically harmful, or when a parent or guardian held sincere religious beliefs opposing vaccination.

That changed in 2019.

Following a major measles outbreak centered in communities with clusters of unvaccinated children, New York lawmakers repealed the religious exemption while retaining the medical exemption. The state said the change was necessary to maintain high vaccination levels and reduce the risk of communicable-disease outbreaks in schools.

The repeal applied across different school settings. It did not create an exception for private religious schools or community schools serving families with shared religious beliefs.

That broad application became central to the constitutional dispute.

Who Challenged the Law

The plaintiffs included Amish parents, an elected representative of Amish schools in New York and three Amish community schools: Dygert Road School, Pleasant View School and Shady Lane School.

They alleged that their religious beliefs did not permit them to vaccinate their children. They also argued that group education in Amish community schools was important to the religious formation and continuation of their way of life.

The New York Department of Health audited the schools and concluded that unvaccinated students had attended beyond the permitted grace period without documentation of immunization, immunity or a valid medical exemption.

Administrative penalties totaling $118,000 were imposed against the schools. Under the state framework, each day an ineligible student attends can be treated as a separate violation.

The plaintiffs responded by filing a federal civil-rights lawsuit against New York’s health commissioner. They sought an order preventing the state from enforcing the vaccination law against them and a declaration that the law was unconstitutional as applied to their communities.

Why the Case Returned to the Second Circuit

A federal district court dismissed the lawsuit, and the Second Circuit initially affirmed that dismissal in March 2025.

The plaintiffs then asked the U.S. Supreme Court to review the case.

Rather than deciding the constitutional question itself, the Supreme Court vacated the Second Circuit’s earlier judgment and sent the case back for reconsideration in light of Mahmoud v. Taylor.

Mahmoud involved parents who objected on religious grounds to LGBTQ+-inclusive books used in Maryland elementary schools. The Supreme Court concluded that the parents were likely entitled to greater constitutional protection because the school system had declined to provide an opt-out from instruction they believed conflicted with their faith.

The Amish plaintiffs argued that the same reasoning should apply to New York’s vaccination law.

The Second Circuit disagreed.

Why the Court Said Mahmoud Did Not Change the Result

The appeals court drew a distinction between curriculum and a public-health requirement.

According to the court, New York’s vaccination law does not tell children what religious or moral ideas they must accept. It does not require them to affirm a belief, participate in ideological instruction or study materials intended to influence their religious development.

Instead, it establishes a condition for attending school in person.

The judges acknowledged that the burden on the Amish families could be serious. However, they concluded that it was not the same kind of governmental interference involved when schools expose children to instruction that directly conflicts with their parents’ religious teaching.

The court therefore found that Mahmoud did not require a different outcome in Miller.

That distinction may become important in future educational-law cases. Courts may treat parental objections to curriculum differently from objections to generally applicable health, safety or administrative requirements.

The Court Found the Law Neutral Toward Religion

Another major issue was whether the New York law discriminates against religion.

Under the Supreme Court’s Free Exercise Clause cases, laws that target religious conduct or treat comparable secular conduct more favorably may be subject to strict scrutiny. That is an extremely demanding legal standard.

By contrast, a law that is neutral toward religion and generally applicable may receive rational-basis review, which is much easier for the government to satisfy.

The Second Circuit concluded that New York’s law is neutral because it does not single out Amish families, religious schools or any particular belief.

The law applies to students across public, private and parochial schools. The remaining medical exemption is based on the physical risks vaccination could pose to an individual child, not on whether the child or family holds a favored secular belief.

The court therefore did not treat the medical exemption as evidence that New York was discriminating against religion.

Why the Medical Exemption Remains

The medical exemption continues to be available when a physician determines that a required vaccine would be detrimental to a child’s health and provides the documentation required by state law.

Legally, the medical exemption serves a different purpose from the former religious exemption.

It does not excuse a family because of a competing belief or personal objection. It addresses situations in which vaccination itself may create a documented health risk.

Courts have generally been willing to distinguish medical exemptions from religious exemptions because the two categories are not considered directly comparable.

This reasoning was important to the Second Circuit’s conclusion that New York had not created a system favoring secular objections over religious ones.

Why the State Repealed the Religious Exemption

New York’s 2019 repeal followed the country’s most serious measles outbreak in more than 25 years. New York was the center of much of that outbreak, and cases were concentrated in communities with significant numbers of unvaccinated people.

Legislative records cited by the court showed that hundreds of New York schools had vaccination rates below the level public-health officials considered necessary to reduce the risk of outbreaks.

Some schools had rates far below the statewide target. In several Rockland County schools located near the center of the measles outbreak, the percentage of students claiming religious exemptions reportedly reached approximately 20%.

Lawmakers viewed those clusters as a threat not only to voluntarily unvaccinated children but also to infants, medically vulnerable students and people who could not receive particular vaccines for legitimate health reasons.

The repeal therefore reflected a public-health judgment: allowing religious exemptions could create pockets of low vaccination coverage capable of sustaining disease transmission.

Why Religious Families Oppose the Law

For the plaintiffs, the dispute was not primarily about statistics or statewide vaccination rates.

They argued that the law forced them into an impossible choice.

They could vaccinate their children in violation of sincere religious beliefs, close their community schools or prevent their children from receiving the kind of group education they considered essential to Amish religious and cultural life.

That burden is not trivial.

Private religious schools often exist because families want children to receive an education connected to their beliefs, traditions and community. When a state requirement makes attendance impossible for some families, the effect can be much greater than an ordinary administrative inconvenience.

The Second Circuit did not deny the seriousness of that burden. It ruled that the Constitution did not require New York to create a religious exemption from a generally applicable school-health law.

The Difference Between a Constitutional Right and a Legislative Exemption

The decision does not mean New York is forbidden from restoring a religious exemption.

It means the federal Constitution does not require the state to provide one under the circumstances presented in this case.

The New York Legislature could choose to amend the law in the future. It could create a broad religious exemption, a narrower exemption for certain schools or a different arrangement involving testing, outbreak exclusions or other conditions.

Whether such a policy would be wise is a separate public-health and political question.

The court’s role was narrower. It had to decide whether the current law violates federal constitutional protections.

The Second Circuit concluded that it does not.

What the Decision Means for New York Schools

For public-school districts, private schools and religious schools, the practical result is continuity.

Schools must continue applying the state’s vaccination requirements to students seeking in-person attendance. They cannot independently create a religious exemption that state law no longer recognizes.

Administrators must also carefully review requests presented as medical exemptions. Those requests require appropriate documentation and cannot simply substitute a parent’s objection for a physician’s medical judgment.

Schools that knowingly allow noncompliant students to attend may face enforcement action and financial penalties.

The case also demonstrates that private and parochial schools are subject to important health-and-safety rules even when they receive no public funding and primarily serve a distinct religious community.

Religious status does not automatically remove a school from generally applicable state regulation.

Could the Case Reach the Supreme Court Again?

The plaintiffs may seek additional review, although the Supreme Court is not required to accept the case.

The procedural history makes the dispute unusually significant. The Supreme Court had already instructed the Second Circuit to reconsider its earlier decision in light of Mahmoud.

The appeals court has now explained why it believes Mahmoud does not apply in the same way to school vaccination requirements.

A future petition could argue that the Second Circuit interpreted parental religious rights too narrowly or failed to give sufficient weight to the combined effect of free-exercise and parental-rights claims.

The state would likely respond that the court correctly distinguished direct religious instruction from neutral public-health regulation.

Until a higher court intervenes or the legislature changes the law, the Second Circuit’s decision remains controlling for the New York case.

Broader Implications for Educational Law

Miller v. McDonald is about vaccines, but its implications extend beyond immunization.

Schools regularly enforce rules that conflict with individual religious, philosophical or parental objections. These may involve curriculum, dress, attendance, health screenings, student identification, athletic participation or safety requirements.

The case suggests that courts will closely examine what a rule actually regulates.

A policy aimed at influencing what children believe may receive more demanding constitutional scrutiny. A neutral health-and-safety condition applied across religious and nonreligious institutions may receive greater judicial deference.

That line will not always be easy to draw.

Many school policies affect family life and religious practice even when they are not written to address religion. Courts must determine when those effects are constitutionally significant enough to require exemptions.

The Public-Health Argument

Supporters of New York’s law argue that vaccination differs from many personal medical choices because communicable diseases affect other people.

Schools bring large groups of children together for extended periods. That environment can allow illnesses to spread quickly, especially when vaccination rates fall within a particular school or community.

Students with medical exemptions may depend on high community vaccination levels because they cannot receive the same protection themselves.

From that perspective, removing religious exemptions is not an effort to punish religious belief. It is an attempt to prevent the choices of one family from increasing health risks for other students.

The Second Circuit accepted that New York had a rational public-health basis for applying the requirement broadly.

The Religious-Liberty Argument

Opponents respond that constitutional protections are most important when government policy places serious pressure on minority faiths.

A requirement that seems neutral to most families may effectively exclude a religious community from operating its schools according to its beliefs.

They also question whether states should be able to eliminate religious exemptions while retaining broad authority over how medical exemptions are defined and approved.

For these families, the issue is not whether vaccination has public-health benefits. It is whether the government must pursue those goals through the least restrictive approach available when sincere religious practice is burdened.

The Second Circuit concluded that strict scrutiny did not apply, so New York was not required to prove that its policy was the least restrictive possible method.

That legal conclusion is precisely why the classification of the law as neutral and generally applicable mattered so much.

What Families Should Understand

The ruling does not eliminate medical exemptions, nor does it mean every student must receive every vaccination regardless of health.

It confirms that religious objections alone do not create an exemption under current New York law.

Families should communicate with schools early, especially when a child has a medical condition that may affect vaccination. Required documentation should be obtained from qualified medical professionals rather than waiting until the school year begins.

Parents who disagree with the law may advocate for legislative change or pursue further litigation. Schools, however, must follow the law currently in effect rather than creating exceptions based on individual preference.

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Key Takeaways

The Second Circuit ruled on June 30, 2026, that New York’s elimination of religious exemptions from school vaccination requirements does not violate the federal Constitution. The New York State School Boards Association published its legal analysis on July 20.

The lawsuit was brought by Amish parents, community schools and an Amish school representative who argued that the vaccination requirement burdened religious exercise and parental authority.

The U.S. Supreme Court had ordered the Second Circuit to reconsider the case in light of Mahmoud v. Taylor, but the appeals court concluded that a school-health requirement differs from mandatory exposure to disputed curriculum.

New York’s medical exemption remains available when vaccination would be detrimental to a child’s health and the required medical documentation is provided.

The decision does not prevent the New York Legislature from restoring a religious exemption. It means the court found that the Constitution does not require one under the current legal framework.

Frequently Asked Questions

Did New York adopt a new vaccine law in July 2026?

No. The court upheld the existing law. New York repealed its religious exemption in 2019.

When did the court issue its decision?

The Second Circuit issued its reconsidered decision on June 30, 2026. The New York State School Boards Association published an analysis on July 20.

Are medical exemptions still allowed?

Yes. A medical exemption may be available when a physician determines that vaccination would be detrimental to a child’s health and supplies the required documentation.

Does the law apply to private religious schools?

Yes. New York’s school immunization requirements apply to public, private and parochial schools.

Why did the Supreme Court send the case back?

The Supreme Court instructed the Second Circuit to reconsider the case in light of Mahmoud v. Taylor, a religious-liberty case involving parental objections to classroom materials.

Could New York restore religious exemptions?

Yes. The legislature could amend the law. The court’s decision addressed what the Constitution requires, not what policy lawmakers may choose to adopt.

Final Thoughts

New York’s school-vaccination dispute places two deeply important interests in direct conflict.

Religious families argue that the state has made participation in their own community schools dependent on conduct that violates sincere beliefs. Public-health officials argue that schools cannot protect children from communicable disease when broad exemptions allow clusters of unvaccinated students to develop.

The Second Circuit sided with the state.

Its reasoning rested heavily on the difference between regulating religious development and setting a neutral condition for in-person school attendance. The court concluded that New York’s law addresses health and safety rather than curriculum, belief or worship.

That does not make the burden on the Amish plaintiffs insignificant.

It means the judges did not believe the First Amendment required the state to provide an exemption from a broadly applicable public-health rule.

The decision will likely remain controversial because it reaches beyond vaccines. It helps define how far parental religious rights extend when they collide with laws designed to protect students collectively.

For now, New York schools must continue enforcing the state’s immunization requirements without a religious exemption.

The legal debate may continue, but the operational rule for schools remains clear.

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