The U.S. Supreme Court has vacated a federal appeals court ruling that upheld New York’s elimination of religious exemptions from school vaccination requirements, ordering a new review in light of a recent decision expanding protections for parents’ religious objections to public school policies.
On December 8, 2025, the U.S. Supreme Court issued a brief order in Miller v. McDonald, vacating a decision by the U.S. Court of Appeals for the 2nd Circuit that had upheld New York’s repeal of religious exemptions to its school vaccination requirements.
The case stems from New York’s 2019 decision to end long‑standing religious exemptions for school immunizations following a severe measles outbreak, a move that left only medical exemptions in place. According to the 2nd Circuit’s March 2025 opinion in Miller v. McDonald, lawmakers acted after the United States experienced its worst measles outbreak in more than 25 years, with New York as the epicenter and most cases occurring in communities with clusters of unvaccinated individuals.
The Supreme Court directed the 2nd Circuit to reconsider the dispute in light of its June 27, 2025 ruling in Mahmoud v. Taylor, a 6–3 decision in which the justices held that parents challenging an elementary school’s use of LGBTQ‑inclusive storybooks were entitled to a preliminary injunction on free‑exercise grounds.
In Miller, several Amish parents and three Amish community schools challenged both the 2019 law and financial sanctions imposed for noncompliance. New York’s health commissioner in 2022 upheld penalties ranging from $20,000 to $52,000 against the schools for violations of the law ending religious exemptions, Education Week has reported. The plaintiffs argue that forcing Amish children to be vaccinated to attend their small, private religious schools in rural communities violates their First Amendment right to free exercise of religion.
From 1966 until 2019, New York permitted religious exemptions from school immunization requirements, according to a summary by First Liberty Institute, which represents the Amish schools. After the 2019 repeal, the statewide immunization requirements applied to all students in public, private and parochial schools, except those qualifying for a medical exemption under state law.
The 2nd Circuit rejected the Amish plaintiffs’ claims in its March ruling, concluding that New York’s school immunization statute is neutral and generally applicable and therefore subject only to rational‑basis review. The appeals court cited the state’s interest in protecting public health and sustaining high vaccination rates among schoolchildren, and it distinguished the Amish families’ claims from those in Wisconsin v. Yoder, the 1972 Supreme Court case that allowed Old Order Amish parents to withdraw their children from school after the eighth grade.
In seeking Supreme Court review, the Amish schools and parents urged the justices to either take up the case outright or at least order the 2nd Circuit to revisit its decision in light of Mahmoud. They argued that the high court’s recent ruling had revived elements of Yoder and strengthened protections for parents who say public school requirements burden their religious exercise.
New York officials, in briefs opposing review, argued that Yoder does not extend to vaccination mandates that are aimed at protecting public health, safety and child welfare, and that nothing in Mahmoud undermines that principle, according to coverage by Education Week.
By choosing to vacate and remand rather than decide the merits, the Supreme Court adopted the challengers’ alternative request. The justices’ order leaves New York’s school vaccination requirements in place for now but instructs the 2nd Circuit to reassess its reasoning under the framework announced in Mahmoud.
Press materials from First Liberty Institute describe the Court’s action as a significant step for the Amish families, but the ultimate outcome will depend on how the 2nd Circuit applies the newer precedent. The case could return to the Supreme Court after further proceedings in the lower courts.
New York is among a small group of states that do not currently allow religious exemptions from school vaccination requirements, while many others continue to permit such opt‑outs. Public health authorities have long linked clusters of unvaccinated students to higher risks of outbreaks of vaccine‑preventable diseases, though the legal questions in Miller center on how courts should balance those concerns against parents’ religious liberty claims under the First Amendment.