Phillips v. City of New York

The New York Public Health Law required that children attending public school receive certain mandatory vaccinations. The statute contained only two exemptions, allowing a child to attend school without one or more mandatory vaccinations if (1) a doctor certified that vaccination would be detrimental to the child’s health or (2) vaccination was against the parents’ or guardians’ genuine and sincere religious beliefs. If a child was subject to one of the exemptions, then a state regulation allowed school officials to exclude the child from school if there was an outbreak of a disease for which the child was not vaccinated. Catholics Nicole Phillips and Fabian Mendoza-Vaca (plaintiffs) obtained religious exemptions for their children. The children were temporarily excluded from school when a fellow student was diagnosed with chickenpox. Phillips and Mendoza-Vaca then sued the City of New York and state officials (government parties) (defendants), challenging the constitutionality of the exclusion rule. Dina Check (plaintiff) filed a similar suit challenging the constitutionality of the vaccination requirement after her application for a religious exemption for her daughter was denied. Although Check identified as Catholic, her application did not rely on religious doctrines but instead cited concerns about vaccinations’ medical risks. After the Phillips and Mendoza-Vaca case and the Check case were consolidated, the parents filed an amended complaint specifically alleging that the state’s mandatory vaccination requirement and temporary-exclusion rule violated Fourteenth Amendment substantive due process, the First Amendment’s Free Exercise Clause, and the Fourteenth Amendment’s Equal Protection Clause. The government parties moved to dismiss the amended complaint, and the district court granted the motion. The parents appealed.