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Jacobson v. Massachusetts

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Supreme Court of the United States
Jacobson v. Massachusetts
Reference: 197 US 11
Term: 1905
Important Dates
Argued: December 6, 1904
Decided: February 20, 1905
Outcome
Supreme Court of Massachusetts affirmed
Majority
Chief Justice Melville Fuller • John M. Harlan • Henry B. Brown • Edward D. White • Joseph McKenna • Oliver Holmes • William R. Day
Dissenting
David J. Brewer • Rufus W. Peckham

Jacobson v. Massachusetts is a case decided on February 20, 1905, by the United States Supreme Court that upheld the authority of states to enforce compulsory vaccination laws. In Jacobson the US Supreme Court ruled that individual liberty is not absolute and is subject to the police powers of the states.[1]

HIGHLIGHTS
  • The case: The state of Massachusetts passed a law that allowed cities to require residents to be vaccinated against smallpox. The city of Cambridge adopted a law that required a smallpox vaccine. Pastor Henning Jacobson refused to get a smallpox vaccination and argued that he and his son had bad reactions to earlier vaccinations. He was fined five dollars. He argued that a fine or imprisonment for refusing to get a vaccine was an invasion of his liberty and that the law was unreasonable, arbitrary, and oppressive. He argued that unreasonably, arbitrary, and oppressive laws were prohibited by the Bill of Rights protections incorporated into the states by the Fourteenth Amendment
  • The issue: Do state laws that mandate vaccination violate the individual liberties protected by the Bill of Rights incorporated into the states by the Fourteenth Amendment?
  • The outcome: The U.S. Supreme Court held 7-2 that the law was a legitimate exercise of the state's police power to protect public health and the safety of its citizens.


    • Why it matters: The U.S. Supreme Court's decision in Jacobson v. Massachusetts held that the states have the power to mandate vaccinations under state police powers. The Supreme Court reasoned that local boards of health determined when vaccinations were necessary and that the requirements were not unreasonable or arbitrary.[2]

    Background

    The Board of Health of Cambridge, Massachusetts, in 1902, adopted a regulation that ordered the vaccination of all inhabitants against smallpox. Adults who refused to become vaccinated against smallpox were subject to a $5 fine.

    Henning Jacobson, a pastor in Cambridge who had immigrated from Sweden, refused to receive the vaccination. He argued that he had been given vaccinations as a child and he received bad reactions from previous vaccines. When he refused to receive a vaccine he was fined $5. Jacobson appealed his fine and argued that the vaccine mandate was an invasion of his liberty and that the law was unreasonable, arbitrary, and oppressive. He argued that the vaccination mandate violated the Fourteenth Amendment of the United States Constitution which incorporated the Bill of Rights into the states and protected against arbitrary and oppressive laws that invaded individual liberty.[1]

    Oral argument

    Oral arguments were held on December 6, 1904. The case was decided on February 20, 1905.[2]

    Outcome

    The U.S. Supreme Court ruled 7-2 that the state of Massachusetts had the power to mandate vaccinations under the state police powers.

    Justice John M. Harlan wrote the majority opinion and was joined by Justices Chief Justice Melville Fuller, Henry B. Brown, Edward D. White, Joseph McKenna, Oliver Holmes, and William R. Day.

    Justices David J. Brewer and Rufus W. Peckham dissented from the majority's judgment but did not write a dissenting opinion.[3]

    Opinions

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    Majority opinion

    Justice John Harlan delivered the 7-2 opinion of the United States Supreme Court and ruled that Massachusetts' law requiring smallpox vaccines did not violate the Constitution. Harlan argued that mandatory vaccinations are neither arbitrary nor oppressive as long as they do not "go so far beyond was reasonably required for the safely of the public." He argued that smallpox was "prevalent and increasing in Cambridge" and that regulation was "necessary in order to protect the public health and secure the public safety."[1]

    Harlan argued that it was the role of the legislature, not the courts, to determine whether vaccinations were necessary to protect public health and secure public safety. Because the Massachusetts General Assembly permitted vaccine requirements the city of Cambridge was permitted to require smallpox vaccinations. Harlan argued that Jacobson could not "confidently assert that the means prescribed by the State to that end has no real or substantial relation to the protection of the public health and the public safety." Because the law was necessary to promote public health and public safety, and because the law did not unduly or prejudicially restrict liberty, the US Supreme Court ruled that Massachusetts' vaccination requirements were constitutional.[1]

    Harlan argued that in extreme cases for individuals "in a particular condition of health" it would be cruel and inhumane to require vaccinations. He argued that in those cases it would be necessary for the courts to interdict the requirements to prevent oppression. Harlan ruled that Jacobson's case was not such a case because he "did not offer to prove that, by reason of his then condition, he was, in fact, not a fit subject for vaccination."[1]

    Aftermath

    The U.S. Supreme Court, in Jacobson v. Massachusetts, held that states can require compulsory vaccinations under state police powers without violating the U.S. Constitution. The U.S. Supreme Court affirmed the decision in Jacobson in 1922 in Zucht v. King which held that a school system could refuse admission to a student who refused to receive a vaccination. [4]

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 JUSTIA, Jacobson v. Massachusetts, accessed November 14, 2022
    2. ↑ 2.0 2.1 Oyez, Jacobson v. Massachusetts, accessed November 14, 2022
    3. ↑ Institute for Justice, A tale of two cases and two pandemics, accessed November 14, 2022
    4. ↑ Harvard Law Review, Jacobson v. Massachusetts, accessed November 14, 2022
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