Workman v. Mingo County Board of Education
United States Court of Appeals for the Fourth Circuit
419 F. App’x 348 (2011)
- Written by Meredith Hamilton Alley, JD
Facts
Jennifer Workman (plaintiff) had two children, M.W. and S.W. After S.W. received vaccinations, she started having health problems, so Workman decided not to have M.W. vaccinated. The family lived in West Virginia, where vaccination was required as a condition of attending school unless a physician certified that vaccination of the child was medically improper. The statute did not allow for a religious-based exemption. A psychiatrist provided an exemption certificate for M.W., but the head of the state health department recommended denial of Workman’s medical exemption. Workman sued several state agencies, and the district court dismissed the complaint. Workman appealed, and the appellate court found that the state’s vaccination laws surpassed the strict-scrutiny test and therefore did not overly burden Workman’s right to free exercise of religion. The appellate court then addressed Workman’s argument that denial of a religion-based exemption violated her due-process right to raise her child the way she believed was best.
Rule of Law
Issue
Holding and Reasoning (Wynn, J.)
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