Even though it upheld New York’s decision to ban religious exemptions to vaccine mandates for all schoolchildren, the Second Circuit Court of Appeals must now reconsider its ruling according to SCOTUS’s landmark parental rights case.
The U.S. Supreme Court has directed the U.S. Court of Appeals for the Second Circuit to reconsider their decision in Miller v. McDonald, which upheld New York’s elimination of all religious exemptions from school vaccination requirements.
The case involved three Amish private schools and a group of Amish parents who were penalized for allowing unvaccinated children to attend classes. Their legal representative, First Liberty Institute, argued that New York violated the First Amendment’s Free Exercise Clause when lawmakers repealed the state’s religious exemptions in 2019 while continuing to allow medical exemptions. The repeal followed a significant measles outbreak that year.
In a brief order released last month, the Supreme Court granted a petition to vacate the Second Circuit’s ruling in Miller and ordered it to reconsider the case in light of Supreme Court’s parental rights ruling last June in Mahmoud v. Taylor.
In Mahmoud, the justices ruled that parents have a right to opt their children out of LGBTQ-themed curriculum that conflicts with their religious beliefs. The Court held that parents have the right to challenge government policies that interfere with their faith and that they do not lose their free exercise rights when their children attend public schools.
The Court’s decision to reopen Miller suggests that the Court’s reasoning in Mahmoud may extend beyond curriculum disputes and into other areas where government mandates conflict with religious convictions, including vaccination requirements.
Justice Samuel Alito, writing for the majority in Mahmoud, relied heavily on the Supreme Court’s 1972 ruling in Wisconsin v. Yoder, which limited state authority over Amish education. In that case, the Court held that forcing Amish children to attend high school would impose a substantial burden on their religious practice without a compelling justification.
Alito cited the Yoder decision as a foundation for “robust protection of religious liberty” and reaffirmed that parents have a constitutional right “to direct the religious upbringing of their children.” He warned that laws interfering with that right carry “a very real threat of undermining” religious beliefs and stressed that parental rights extend beyond the home and into the public sphere.
Yoder stated that a law that “substantially” interferes “with the religious development of the Amish child” poses an “objective danger” that the First Amendment is intended to guard against. “The First Amendment forbids compelling children to depart from the religious practices of their parents,” Alito wrote.
Mat Staver, founder and chairman of Liberty Counsel, which is representing a number of similar parental rights and religious liberty cases, hailed the Supreme Court’s order, saying that the decision to send the Miller case back for reconsideration under Mahmoud v. Taylor “shows 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.”
He continued, “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.”
The renewed focus on New York’s removal of religious exemptions comes at a time when public concern about vaccine safety and government authority has grown more intense than in previous decades. Many parents, including those in religious communities, are raising questions about long-term health effects, expanding school mandates, and the speed at which new vaccines are developed and required.
For families whose religious beliefs emphasize stewardship of the body or caution toward certain medical interventions, these concerns are not abstract. Amish communities in particular have long approached healthcare decisions with a desire to weigh medical advice against faith, tradition, and conscience.
Debates over religious exemptions and parental rights can feel technical or political, but for Christians these questions reach far deeper. They touch the heart of what it means to follow Christ in a world where government authority continues to expand into areas that have long belonged to families and churches.
The First Amendment’s Free Exercise Clause is not just a legal protection — it reflects a biblical truth that God alone is Lord of the conscience and that parents carry a sacred calling to raise their children in the nurture and instruction of the Lord.
Scripture teaches that faith is not something the state creates or controls. It is a gift from God, shaped in families, strengthened in community, and lived out through daily obedience. When the government burdens the ability of Christians to make decisions for their children based on conviction, the issue is not simply about policy. It is about whether believers can freely live out their faith with integrity before God.
This is why it is important for Christians to understand what the First Amendment actually protects. Knowing the truth about free exercise helps believers discern when the government is acting within its proper role and when it is stepping into places reserved for the authority of parents or the gathering of God’s people. It also equips families to speak with clarity and confidence when their convictions are challenged.
Christians are called to be both good citizens and faithful disciples. These responsibilities are not in conflict when believers understand their rights and use them to honor God. As Paul used his Roman citizenship to advance the Gospel, modern Christians can use their constitutional protections to safeguard the freedom needed to live out their faith.
The path forward requires courage, humility, and discernment. Families must stay informed. Churches must teach a biblical view of authority and conscience. Believers must pray for wisdom as courts wrestle with these questions. Above all, Christians must remember that our ultimate allegiance is to God, who calls His people to stand firm, speak truth in love, and trust that His purposes endure through every legal ruling and cultural shift.
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