Confirming a significant judicial decision, the US Court of Appeals for the Second Circuit approved Connecticut’s Public Act 21-6, terminating religious exemptions from the state’s immunization requirements. The legislation originally aimed to cover children in schools, students in higher education, and participants in child care.
Circuit Judge Denny Chin shared the court’s primary opinion. He concluded that the case questioning the legality of the law on the basis of the First Amendment Free Exercise Clause fell short, as the law itself retains neutrality and abides by the standards of a rational basis review. Chin further commented on the absence of any discernible ‘hostility’ towards religious believers in the legislative history of the act.
The rationale behind this assertion relies on the neutral and fairly applicable nature of the law, unmarred by substantial under-inclusivity. Upholding the dismissal of the plaintiff’s medical freedom and privacy claims alongside their equal protection claims, Chin highlighted the incomparability of religious and medical exemptions, especially considering the state’s interest in protecting the health and safety of Connecticut’s children and the larger public.
Furthermore, applying a rational basis review, the court would only deem a law constitutional if it was enacted with a legitimate public interest and the statute logically pertained to that interest. According to this standard, laws have a certain prediction of validity. The court also added that laws can surpass rational basis standards as long as they potentially support any viable legitimate purpose.
However, Circuit Judge Joseph F. Bianco penned a partial agreement and partial dissent to the majority opinion. Bianco argued for the plausibility of the plaintiffs’ claim in their First Amendment challenge, contending that the law should undergo strict scrutiny rather than a rational basis review. This, in Bianco’s view, should propel the claim past summary judgment and lead to further proceedings.
In response to this ruling, Connecticut District Attorney William Tong issued a statement. He referred to the decision as a complete and robust affirmation of the constitutionality and legality of Connecticut’s vaccine requirements, underscoring the significance of vaccines in saving lives and pointing out the legislature’s responsible action within its authority in protecting public health.
The original version of this update was published on JURIST.