Miller v. New York State Department of Health

Amish Religious Exemption from Vaccination Requirements

17 minutes
4 participants
Second Circuit Appeal - Cert Petition Pending

Analyzed File

attorney_strategy_discussion.mp3

Legal Issues Identified

Employment Division v. Smith Standard

Whether neutral and generally applicable laws should receive strict scrutiny when they burden religious exercise

92% confidence
Critical

"Some Supreme Court justices have previously voiced their opinion that the Smith decision should be overruled"

Religious Targeting vs. Neutral Application

Whether removing religious exemptions while maintaining medical exemptions constitutes targeting religion

88% confidence
High

"They specifically took away the religious exemption... they ended up targeting religion"

Strict Scrutiny Application

Whether the law fails strict scrutiny due to availability of medical but not religious exemptions

85% confidence
High

"They will give an exemption for medical, but they won't give it for religion. That means it's not generally applicable"

Bodily Autonomy Intersection

Whether forced vaccination implicates bodily autonomy rights that could appeal to liberal justices

78% confidence
Medium

"They're trying to put something into their body so there may be bodily autonomy arguments that the left would be sympathetic to"

Supreme Court Justice Analysis

Justice Alito

95%

Strong supporter of religious liberty, likely to view Smith as problematic precedent

Strategy

Emphasize historical religious persecution and need for constitutional protection

Concerns

None identified - natural ally

Justice Gorsuch

93%

Has explicitly criticized Smith in previous opinions, textualist approach favors religious liberty

Strategy

Focus on textual meaning of Free Exercise Clause and historical understanding

Concerns

None identified - strong ally

Justice Thomas

90%

Originalist approach and strong religious liberty record, likely Smith opponent

Strategy

Historical analysis of Founding Era religious liberty protections

Concerns

None identified - reliable vote

Justice Barrett

75%

Religious liberty supporter but may prefer narrower grounds than overturning Smith

Strategy

Emphasize narrow application to insular religious communities

Concerns

May prefer incremental approach over broad Smith reversal

Justice Kavanaugh

70%

Moderate conservative, may support religious liberty but concerned about broad implications

Strategy

Focus on limited impact to insular Amish communities

Concerns

Worried about broader civil rights implications

Chief Justice Roberts

65%

Institutional concerns may outweigh religious liberty sympathies

Strategy

Emphasize judicial minimalism and narrow ruling possibility

Concerns

Institutional impact of overturning major precedent

Justice Kagan

45%

Liberal justice but may be sympathetic to bodily autonomy and minority rights arguments

Strategy

Frame as minority rights and bodily autonomy issue

Concerns

Generally supports government authority, skeptical of religious exemptions

Justice Sotomayor

40%

Strong government authority supporter, but may consider minority rights angle

Strategy

Emphasize protection of vulnerable minority communities

Concerns

Public health priorities, skeptical of religious exemptions

Justice Jackson

35%

Likely to prioritize public health over religious exemptions

Strategy

Focus on historical persecution of religious minorities

Concerns

Strong public health advocate, skeptical of religious exemptions

Strategic Recommendations

Historical Framing

Pennsylvania Religious Liberty Tradition

Leverage Pennsylvania's unique history as birthplace of American religious liberty

Rationale: Attorneys noted Pennsylvania's colonial experience with religious accommodation led to 'unintended consequence of peace and prosperity'

Target: All justices - appeals to originalist and pragmatic concerns

Implementation

Brief should extensively cite Pennsylvania's colonial religious liberty experiments and their positive outcomes

Sympathetic Plaintiffs

Amish Community Characteristics

Emphasize insular, peaceful nature of Amish communities

Rationale: Attorneys highlighted Amish are 'contained,' 'keep to themselves,' and pose minimal public risk

Target: Moderate conservatives concerned about broader implications

Implementation

Detailed description of Amish insularity, self-sufficiency, and minimal public interaction

Constitutional Principle

Abstention vs. Accommodation Distinction

Distinguish between asking government to do something vs. asking to be left alone

Rationale: Attorneys noted abstention claims are more sympathetic than accommodation demands

Target: Liberal justices concerned about government establishment

Implementation

Frame as simple request to abstain from government-mandated action, not special accommodation

Cross-Ideological Appeal

Bodily Autonomy Arguments

Include bodily autonomy framing to appeal to liberal justices

Rationale: Attorneys identified this as potential bridge to liberal justices

Target: Liberal justices (Kagan, Sotomayor, Jackson)

Implementation

Supplement religious liberty arguments with bodily autonomy principles

Judicial Minimalism

Narrow Ruling Pathway

Provide Court with narrow grounds for ruling without overturning Smith

Rationale: Attorneys acknowledged Court could apply strict scrutiny without Smith reversal

Target: Chief Justice Roberts and Justice Barrett

Implementation

Argue law is not generally applicable due to medical exemption availability

Risk Factors

Vaccine Politics

High Risk

Political sensitivity around vaccines could make justices reluctant to take case

"Because this case deals with vaccines... there may be less desire to deal with this issue"

Mitigation Strategy

Emphasize this involves traditional childhood vaccines, not COVID vaccines

Broad Civil Rights Implications

Medium Risk

Three justices may worry about impact on broader civil rights enforcement

"The biggest deterrent from taking the case... the broader civil rights area"

Mitigation Strategy

Emphasize narrow application to insular religious communities

Public Health Concerns

Medium Risk

Liberal justices may prioritize public health over religious liberty

"The more liberal judges might not want to deal with this case"

Mitigation Strategy

Argue limited public health impact from insular Amish communities

Predicted Opposition Arguments

Public Health Emergency Powers

Strong

State will argue broad authority to protect public health through vaccination requirements

Counter-Strategy

Distinguish from true emergencies; emphasize targeted nature of religious exemption removal

Equal Treatment Principle

Medium

State will argue religious exemptions provide unfair advantage over secular objectors

Counter-Strategy

Emphasize constitutional special status of religious liberty; distinguish from secular preferences

Slippery Slope Concerns

Medium

State will argue religious exemptions could undermine all public health measures

Counter-Strategy

Emphasize narrow application to insular communities with minimal public interaction