The U.S. Supreme Court on Monday vacated a ruling (Miller v. McDonald) of the U.S. Court of Appeals for the Second Circuit, which had rejected a challenge by Amish parents against a New York state law requiring schoolchildren to receive vaccines. The order directed the appellate to reexamine the case “in light of Mahmoud v. Taylor,” a parental rights ruling the Supreme Court issued this past June.

The case involved a 2019 New York law that eliminated religious exemptions from school vaccination requirements. New York allowed religious exemptions from 1966 until 2019. However, during the first Trump administration, the New York legislature removed that exemption, particularly because of Amish communities. New York still allows medical exemptions from school vaccination requirements.

In 2022, New York state initiated enforcement actions against two Amish schoolhouses, ultimately imposing fines of more than $100,000. First Liberty, which is representing the Amish families, noted that the state wanted “to compel Amish schoolchildren — who attend private Amish-only schools in rural Amish communities removed from the modern world — to receive vaccinations in violation of their sincerely held religious beliefs in order to attend Amish community schools.”

Amish parents responded with a lawsuit, seeking an injunction against the law, which threatened to ruin their small, country schools, in addition to burdening their religious beliefs.

“The Amish community in New York wants to be left alone to live out their faith just like they have for 200 years,” urged Kelly Shackelford, president, CEO, and chief counsel at First Liberty. “Who is the authority over our children? Their parents or government bureaucrats? Ultimately, this case will affect every American — their religious freedoms and the authority of every parent to raise their children according to their faith.”

However, both the district court and the 2nd Circuit sided with New York state. The courts reasoned that the law had a general application and was not passed with discriminatory intent; therefore, the proper standard of review was the bottom-shelf rational basis test, which the law passed. This follows the reasoning from the Supreme Court’s Smith (1990) decision, which applies in states without a Religious Freedom Restoration Act.

However, in a move that may signal interest on the Supreme Court in revisiting its Smith precedent, the court vacated the Second Circuit’s ruling and returned the case, directing it to issue a new opinion that took into consideration the Supreme Court’s 2025 decision, Mahmoud v. Taylor.

In Mahmoud, the Supreme Court found that the public school district in Montgomery County, Md. had unconstitutionally burdened the religious exercise of parents by infusing pro-LGBT indoctrination throughout the curriculum and refusing to provide an opt-out. The case was challenged by parents from multiple religions, including Christianity and Islam.

In writing for the 6-3 Mahmoud majority, Justice Samuel Alito wrote, “A government burdens the religious exercise of parents when it requires them to submit their children to instruction that poses ‘a very real threat of undermining’ the religious beliefs and practices that the parents wish to instill. And a government cannot condition the benefit of free public education on parents’ acceptance of such instruction.”

At the very least, the court order for the Second Circuit to reexamine the case in light of this new precedent signals that the court believes the religious exercise of parents should extend beyond the Mahmoud precedent. While that case dealt only with education, the court has now ordered the Second Circuit to apply its reasoning to a health care decision as well.

Both Mahmoud and now Miller v. McDonald signal a new pattern, where the Supreme Court is combining parental rights with the parents’ right to free exercise of religion, reflecting an (accurate) understanding that parental rights are grounded in part on a religious basis.