Jacobson v. Massachusetts
197 U.S. 11 (1905)
Rule of Law:
Under its police power, a state may enact a compulsory vaccination law to protect public health and safety, and such a law does not violate the liberty rights secured by the Fourteenth Amendment so long as it is a reasonable regulation and not an arbitrary or oppressive abuse of power.
Facts:
- In response to an outbreak of smallpox, the Board of Health of Cambridge, Massachusetts, adopted a regulation requiring all inhabitants of the city to be vaccinated.
- This regulation was authorized by a Massachusetts state statute which granted local boards of health the power to require vaccination to protect public health.
- Henning Jacobson, an adult resident of Cambridge, refused to comply with the vaccination regulation.
- Jacobson contended that he had suffered negative health consequences from a previous vaccination as a child and had witnessed similar adverse effects in his son.
- Jacobson argued that the law was an unreasonable invasion of his personal liberty to care for his own body and health.
Procedural Posture:
- Henning Jacobson was subjected to a criminal complaint in a Massachusetts state court for violating the compulsory vaccination order.
- At trial, Jacobson's offer to present evidence challenging the safety and efficacy of vaccination was excluded by the court.
- Jacobson was convicted and ordered to pay a five-dollar fine.
- Jacobson, as the appellant, appealed the conviction to the Supreme Judicial Court of Massachusetts, the state's highest court.
- The Supreme Judicial Court of Massachusetts affirmed the lower court's judgment, upholding the conviction.
- Jacobson then appealed to the Supreme Court of the United States.
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Issue:
Does a Massachusetts statute compelling vaccination for adults during a smallpox epidemic, enforceable by fine or imprisonment, violate the liberty interest protected by the Fourteenth Amendment of the United States Constitution?
Opinions:
Majority - Mr. Justice Harlan
No, the Massachusetts statute does not violate the liberty interest protected by the Fourteenth Amendment. The Constitution does not grant an absolute right for an individual to be free from all restraint; rather, personal liberty must sometimes yield to regulations enacted for the common good and to protect public health. States possess inherent police powers to enact reasonable health and safety laws, and the legislature is the primary body to determine the necessity of such measures. A compulsory vaccination law is a reasonable exercise of this power during an epidemic, as it has a real and substantial relation to protecting the community. Courts should only intervene if such a law is an arbitrary, unreasonable, or palpable invasion of rights, which was not the case here, given the widespread medical and public belief in vaccination's efficacy against smallpox.
Dissenting - Mr. Justice Brewer and Mr. Justice Peckham
Mr. Justice Brewer and Mr. Justice Peckham dissented without a written opinion.
Analysis:
Jacobson v. Massachusetts establishes the foundational legal principle that a state's police power to protect public health can justify limitations on individual liberty. This decision affirms that personal autonomy is not absolute and must be balanced against the welfare of the community, especially during a public health crisis. It sets a high standard for challenging public health measures, granting significant deference to legislative judgment and requiring that a law be proven arbitrary or wholly unrelated to its public health goal to be struck down. The case remains a cornerstone of public health law, frequently cited to support government authority for quarantines, mandatory testing, and vaccination requirements.
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