Will New York’s Amish Really Leave? Inside the Vaccine Mandate Fight Heading Back Toward the Supreme Court
A legal fight involving three small Amish schools in New York has grown into a constitutional dispute that could affect religious liberty, parental rights, vaccination laws, and the future of one of America's largest Amish populations.
Three Amish community schools have been fined a combined $118,000 for allowing children without the required vaccinations to attend classes. Their families argue that compliance would violate sincerely held religious beliefs. New York argues that its vaccination law protects children and the wider public from communicable diseases and applies neutrally to religious and nonreligious families alike.
Now the conflict is approaching the U.S. Supreme Court for a second time.
After the Supreme Court vacated an earlier appellate ruling in December 2025 and ordered the Second Circuit to reconsider the case, the appeals court again ruled against the Amish plaintiffs on June 30, 2026. Their attorneys have announced that they intend to return to the Supreme Court.
Recent reports have added another dramatic possibility: some Amish families say that if they ultimately cannot operate their schools according to their religious convictions, they may leave New York for states where religious vaccination exemptions remain available.
But headlines describing a coming "mass exodus" require context.
There is no announced date on which New York's entire Amish population plans to depart, nor is every Amish person in the state a plaintiff in this case. The legal dispute involves specific parents and three schools, although its outcome could have much broader consequences.
The real story is therefore more complicated than a confrontation between "the Amish" and "vaccines."
It is a constitutional collision between two principles deeply rooted in American law: the government's authority to protect public health and the freedom of religious communities to raise and educate their children according to their faith.
What Is Happening With New York's Amish Vaccine Case?
The lawsuit is called Miller v. McDonald.
The plaintiffs include Amish parents, an elected representative of Amish schools in New York, and three Amish community schools:
- Dygert Road School
- Pleasant View School, also identified in records as Twin Mountain or Twin Mountains School
- Shady Lane School
They sued New York officials after the state enforced its school-immunization law against the schools.
New York Public Health Law Section 2164 requires children attending public, private, and religious schools to receive specified vaccinations unless they qualify for a medical exemption.
The state no longer provides a religious exemption for schoolchildren.
The Amish plaintiffs contend that vaccination conflicts with sincerely held religious convictions and that group education within Amish community schools is itself essential to the religious development of their children.
That places them, they argue, in an impossible position:
Vaccinate their children contrary to their beliefs, stop sending them to Amish community schools, or leave a state in which their families have established religious communities.
Why Did New York Eliminate Religious Vaccine Exemptions?
New York had recognized both medical and religious exemptions for school immunization for decades.
That changed on June 13, 2019.
Then-Governor Andrew Cuomo signed legislation eliminating nonmedical exemptions, including religious exemptions, from vaccination requirements for children attending public, private, and parochial schools.
The state retained medical exemptions for children who have valid medical contraindications to particular vaccines.
The change followed one of the most serious U.S. measles outbreaks in decades.
During 2019, the United States recorded 1,249 measles cases, the highest annual number since 1992. The CDC found that 89 percent of patients were unvaccinated or had an unknown vaccination status.
Two prolonged outbreaks involving close-knit Orthodox Jewish communities in New York City and New York State accounted for 934 cases.
The 2019 outbreak that motivated lawmakers was therefore not principally an Amish outbreak.
That distinction matters.
New York adopted a statewide rule after outbreaks concentrated largely in other undervaccinated religious communities. The resulting law nonetheless applied equally to Amish schools.
Why Were Religious Exemptions Considered a Public-Health Problem?
The state's argument focused on vaccination coverage rather than the theology of any particular community.
Measles is exceptionally contagious.
When vaccination coverage drops substantially within a geographically or socially concentrated group, an imported infection can spread rapidly even if vaccination rates are high statewide.
During the 2018–2019 New York outbreak, some schools in affected Rockland County communities had vaccination rates far below the statewide average.
CDC investigators reported that documented measles vaccination coverage in schools in the outbreak area was about 77 percent, compared with a statewide survey figure of approximately 98 percent.
The Second Circuit later noted that as many as 20 percent of students in six schools in the Rockland County outbreak area had religious exemptions.
New York lawmakers concluded that reducing nonmedical exemptions would make it harder for pockets of highly susceptible children to develop in schools.
What Vaccines Does New York Require for School?
New York currently requires schoolchildren to receive age-appropriate doses of several vaccines.
Depending on age and grade, requirements include protection against:
- diphtheria;
- tetanus;
- pertussis;
- hepatitis B;
- measles;
- mumps;
- rubella;
- polio;
- varicella, or chickenpox;
- meningococcal disease for specified older grades.
The precise number of doses depends on the child's age, prior vaccination history, grade, and vaccine schedule.
New York's Department of Health states that the requirements apply to public, private, and religious schools unless a student has a valid medical exemption.
How Did Three Amish Schools End Up With $118,000 in Fines?
The immediate enforcement dispute began after New York's Department of Health audited the schools in November and December 2021.
By March 2022, the department concluded that students had attended the schools beyond the statutory grace period without proof of required vaccination, evidence of immunity, or valid medical exemptions.
Administrative charges followed.
The New York Commissioner of Health eventually imposed:
- $52,000 against Dygert Road School;
- $46,000 against Pleasant View/Twin Mountain School;
- $20,000 against Shady Lane School.
Total: $118,000.
Under the statute, each violation can carry a penalty of as much as $2,000.
The Department of Health treats each day that an unvaccinated child attends school in violation of the law as a separate violation.
That means potential penalties can accumulate rapidly.
The Second Circuit noted that the commissioner actually described the $118,000 assessment as conservative because the state could have calculated substantially more days of noncompliance.
For small, locally supported Amish schoolhouses, however, even the fines already imposed represent enormous financial pressure.
Why Are the Fines So Important to the Religious-Liberty Argument?
The plaintiffs are not simply objecting to a rule written in a government handbook.
They argue that the financial penalties threaten the continued existence of their schools.
Amish community education is closely connected to the community's broader religious structure.
Small Amish schools are generally designed to educate children within a cultural environment that emphasizes community, religious formation, practical skills, simplicity, and separation from many aspects of mainstream society.
The plaintiffs told the courts that learning together in an Amish group setting is an important component of their children's spiritual development.
They therefore reject the suggestion that simply homeschooling each child individually provides an equivalent alternative.
That argument transforms the dispute from a straightforward vaccination case into a parental-rights and religious-education case.
The Case Has a Famous Amish Precedent Behind It
The Amish plaintiffs rely heavily on one of the most important religious-liberty decisions in American history: Wisconsin v. Yoder.
In 1972, the Supreme Court considered Amish parents who refused to send their children to formal school beyond the eighth grade.
Wisconsin argued that compulsory education served an important state interest.
The Amish argued that high-school education would expose their children to values fundamentally incompatible with their religious way of life.
The Supreme Court sided with the Amish.
It held that the state's interest in compulsory education had to be balanced against the parents' Free Exercise rights and their traditional authority over the religious upbringing of their children.
For today's plaintiffs, the parallels seem powerful.
Once again:
- Amish parents are involved;
- education is involved;
- a state requirement conflicts with religious practice;
- penalties place pressure on families to comply;
- and parents argue that compliance would interfere with the continuation of Amish religious life.
But New York says the analogy breaks down at a critical point.
Why New York Says Vaccination Is Different From Yoder
The state argues that requiring vaccination before attending school does not control what Amish children are taught.
It does not require them to study a belief contrary to their religion.
It does not require them to affirm a worldview.
It does not place them in a non-Amish school.
Instead, according to the state and the Second Circuit, vaccination is a health-and-safety condition attached to physical school attendance.
The appellate court emphasized exactly this distinction in June 2026.
It held that New York's law "does not regulate what children are taught," require children to affirm beliefs, or insert state-selected religious or ideological instruction into Amish schooling.
Instead, it seeks to reduce transmission of communicable disease.
That difference became decisive.
Why Did the Supreme Court Get Involved in 2025?
The first round of Miller v. McDonald did not go well for the Amish plaintiffs.
A federal district court dismissed their constitutional claims in March 2024.
The Second Circuit affirmed on March 3, 2025.
The plaintiffs then petitioned the U.S. Supreme Court.
While their petition was developing, the Supreme Court decided another major religious-parental-rights case: Mahmoud v. Taylor.
That case involved parents in Maryland who objected to their young children being exposed to certain LGBTQ+-inclusive storybooks in public schools without an opt-out.
In June 2025, the Supreme Court ruled 6–3 that the parents were entitled to preliminary relief.
The Court treated parental religious formation as a serious Free Exercise interest rather than limiting Yoder to its unusual Amish facts.
That decision gave the New York Amish plaintiffs a potentially important new argument.
The Supreme Court Vacated the First Second Circuit Ruling
On December 8, 2025, the Supreme Court granted the Amish plaintiffs' petition, vacated the Second Circuit's judgment, and sent the case back.
The appeals court was instructed to reconsider Miller v. McDonald in light of Mahmoud v. Taylor.
This procedure is sometimes called a GVR:
- grant;
- vacate;
- remand.
It was significant, but it was not a final ruling that the Amish had won their constitutional claim.
The Supreme Court did not itself order New York to create a religious vaccine exemption.
It instructed the lower court to reconsider the case using the Supreme Court's newer parental-rights precedent.
That distinction became crucial six months later.
Why Did the Second Circuit Rule Against the Amish Again?
On June 30, 2026, the same appellate court reconsidered the case.
It again sided with New York.
The Second Circuit accepted that Mahmoud had expanded the significance of Yoder beyond the exact historical circumstances of Amish secondary education.
But it concluded that vaccination imposes a different kind of burden.
According to the court, Yoder and Mahmoud involved government interference with the religious development of children through education.
New York's vaccination law involves a condition designed to protect health when children gather physically at school.
The court described the burden as potentially serious but not "of the same character" as the burdens considered in Yoder and Mahmoud.
As a result, the court declined to subject the law to the demanding constitutional test known as strict scrutiny.
What Does "Neutral and Generally Applicable" Mean?
This legal phrase is at the center of the case.
Under existing Free Exercise doctrine, a law that deliberately targets religion normally faces severe constitutional scrutiny.
But a neutral law that applies generally to religious and secular conduct can often remain valid even when it incidentally makes religious practice more difficult.
The Second Circuit concluded that New York's vaccination law is neutral on its face.
It does not say:
"Amish children must be vaccinated."
It says that children attending schools must satisfy immunization requirements unless they qualify for the medical exception.
The court also found no sufficient evidence that lawmakers repealed the religious exemption because they were hostile to Amish beliefs or religion generally.
Because the law was found neutral and generally applicable, the court applied rational-basis review, a much easier constitutional standard for the government to satisfy.
The plaintiffs conceded that reducing vaccine-preventable disease is a legitimate governmental interest.
Then Why Is There Still a Medical Exemption?
This may be the most intuitive question in the entire case.
If New York can exempt a child for medical reasons, the Amish argue, why can it not exempt a child for sincere religious reasons?
In modern Free Exercise cases, a government can sometimes trigger strict scrutiny when it gives favorable treatment to comparable secular reasons for avoiding a rule while rejecting religious reasons.
The plaintiffs therefore argue that the medical exemption undermines the claim that vaccination is universally necessary.
The Second Circuit rejected that comparison.
Its reasoning was that a medical exemption serves rather than undermines the health objective of the law.
A child receives such an exemption because a particular vaccination may itself be medically contraindicated for that child.
The exemption is tied to documented health criteria and may apply only to particular vaccines or for a particular period.
By contrast, the court reasoned, a broad religious exemption increases the number of students who remain susceptible for reasons unrelated to a medical inability to receive vaccination.
Whether the Supreme Court agrees with that distinction may become an important issue if it takes the case again.
What Do Older Supreme Court Cases Say About Vaccine Mandates?
The constitutional history does not begin with COVID-19.
In Jacobson v. Massachusetts in 1905, the Supreme Court upheld state authority to impose a smallpox vaccination requirement under its public-health powers.
Importantly, that case involved a monetary penalty rather than government officials physically forcing vaccination.
Then, in Zucht v. King in 1922, the Supreme Court upheld the exclusion of unvaccinated children from schools under a municipal vaccination requirement.
Those decisions provide states with substantial historical support for vaccination laws.
But modern religious-liberty jurisprudence has also evolved considerably, especially in cases involving government exemptions, unequal treatment of religious conduct, and parental rights.
That is why Miller is not simply a rerun of a 1905 vaccine case.
The constitutional framework surrounding it is much more complicated.
Are the Amish Opposed to All Modern Medicine?
No.
That description is too broad.
Amish health practices vary substantially between communities, church affiliations, families, and individuals.
Research has found lower vaccination uptake in many Amish populations, but it has also repeatedly cautioned against assuming that all Amish families reject vaccination or modern health care.
A large review of Amish health research found considerable variation in childhood vaccination practices between Amish communities. Some surveyed communities had high levels of partial vaccination, while relatively small minorities in certain settlements had completely unvaccinated households.
The review also found that objections were not always primarily theological; concerns about side effects and safety could play an important role.
An earlier study of an Old Order Amish community in Illinois likewise concluded that Amish families did not universally reject vaccines and that resistance was not necessarily based on religion.
The current New York lawsuit therefore concerns the sincerely held beliefs of these plaintiffs and their communities.
It should not be treated as proof that every Amish person holds an identical position.
Why That Distinction Matters
The Amish are decentralized.
There is no single worldwide Amish pope, president, or central governing body issuing health-care rules to every community.
Local church districts operate with considerable autonomy.
Practices can differ regarding:
- technology;
- transportation;
- medical care;
- telephones;
- electricity;
- clothing details;
- occupations;
- schooling;
- insurance;
- vaccination.
Even within broadly similar Amish affiliations, individual families may make different medical decisions.
So the phrase "the Amish reject modern medicine" creates a misleading picture of a diverse religious population.
It is more accurate to say that many Amish communities approach modern health institutions selectively and that some have low vaccination rates.
How Large Is New York's Amish Population?
It is substantial—and growing.
The Young Center for Anabaptist and Pietist Studies estimated that New York had approximately 26,320 Amish residents in 2026.
They were distributed across:
- 64 settlements;
- 198 church districts.
That makes New York one of the major centers of Amish population in North America.
The community has also expanded rapidly over recent decades, largely because Amish families tend to be large and retention into adulthood is comparatively high.
That is why reports of a possible exodus have attracted national attention.
Even the relocation of a meaningful fraction of these communities could affect rural areas where Amish families have purchased farms, established businesses, and built schools.
Is a Mass Amish Exodus From New York Really About to Happen?
Not yet, based on the publicly documented evidence.
Attorneys representing the plaintiffs have said that families may leave if New York ultimately makes their religious schooling impossible under the vaccination requirement.
Recent reporting describes Pennsylvania as one possible destination.
Pennsylvania is an obvious comparison because it has America's largest Amish population and currently recognizes exemptions to school immunization requirements based on medical reasons, religious belief, and strong moral or ethical conviction.
But there is an important difference between:
"Some families say they would relocate if they lose"
and:
"26,000 Amish residents have collectively decided to leave New York."
The latter has not been established.
Amish communities are decentralized, and migration decisions typically occur through families, church districts, and settlements rather than through a single statewide command.
"Mass exodus" therefore captures the potential stakes but should not be mistaken for a scheduled statewide departure.
Why Would Moving Be More Than Changing an Address?
For an Amish family, relocation can involve rebuilding an entire community infrastructure.
A viable settlement needs more than farmland.
Families may need access to:
- other Amish households;
- a church district;
- compatible agricultural or trade opportunities;
- Amish schools;
- transportation arrangements;
- markets for businesses and farms;
- affordable land;
- relationships with neighboring communities.
The Amish historically do create new settlements when local conditions become unfavorable.
The Young Center notes that access to affordable land, rural isolation, suitable economic conditions, proximity to similar communities, and government environments compatible with Amish life can all influence migration and settlement formation.
A state policy that makes community schooling impossible for a particular Amish affiliation could therefore influence migration decisions in a way that would not affect a typical suburban household.
What Is New York's Strongest Argument?
New York's strongest argument is collective risk.
A school vaccination law does not regulate only the health of the family choosing vaccination or nonvaccination.
Communicable diseases can spread from one child to another.
Some people cannot safely receive particular vaccines because of genuine medical conditions.
Infants may be too young for routine doses.
No vaccine is perfectly effective for every recipient.
The state therefore argues that vaccination coverage operates partly as community protection.
The 2019 measles experience provides concrete evidence for that concern.
According to the CDC, 89 percent of U.S. measles patients in 2019 were unvaccinated or had unknown vaccination status, and most cases occurred in outbreaks concentrated in undervaccinated close-knit communities.
For the state, allowing broad religious exemptions could recreate precisely the conditions lawmakers sought to prevent.
What Is the Amish Plaintiffs' Strongest Argument?
Their strongest argument is not that infectious disease is imaginary or that New York has no public-health authority.
It is that constitutional rights sometimes require governments to accommodate sincere religious practice even when a general policy serves an important goal.
They emphasize several features of their circumstances:
- the schools are privately operated Amish institutions;
- the families seek to educate children within their own religious communities;
- the religious objections are alleged to be sincere;
- New York accommodated religious exemptions for decades;
- medical exemptions still exist;
- financial penalties can threaten the viability of community schools;
- compulsory compliance would involve an irreversible physical intervention.
They also invoke the historic protection given to Amish family life in Wisconsin v. Yoder.
After Mahmoud, they argue that courts should take the combined burden on religion and parental authority more seriously.
Why Mahmoud v. Taylor Could Still Matter
The Supreme Court's December 2025 decision to vacate the earlier Miller judgment suggests that at least the Court believed Mahmoud deserved consideration.
But that does not tell us what the justices will ultimately decide.
The Second Circuit interpreted Mahmoud narrowly enough to distinguish vaccination from religious education.
The Amish plaintiffs will likely argue that this focuses too much on the subject matter of the regulation and not enough on its practical effect on religious child-rearing.
Their position is essentially:
If a state cannot substantially interfere with religious formation by forcing children into objectionable educational exposure, why should it be able to make an irreversible medical procedure the price of attending the religious schools through which that formation occurs?
New York's answer is equally straightforward:
Because vaccination protects third parties from infectious disease in a way that curriculum disputes do not.
That is the constitutional fault line.
Could the Supreme Court Take the Case Again?
Yes.
Attorneys representing the Amish plaintiffs have publicly stated that they intend to petition again after the June 2026 Second Circuit decision.
As of September 2, 2026, the Supreme Court's public materials still prominently show the earlier petition, docketed as No. 25-133, which resulted in the December 2025 vacatur and remand. The next petition following the June 2026 ruling has been publicly promised by counsel, but the earlier docket itself does not represent a final merits decision in the plaintiffs' favor.
If a new petition is filed, the justices will decide whether to grant review.
Most Supreme Court petitions are denied.
But this case has an unusual characteristic:
The Supreme Court has already intervened once.
That does not guarantee another hearing, but it gives the dispute more significance than an ordinary unsuccessful appellate challenge.
What Could Happen if the Supreme Court Takes the Case?
Several broad outcomes are possible.
The Court could uphold the Second Circuit
That would leave New York's law intact as applied to the Amish plaintiffs.
Religious objections would not create a constitutional entitlement to exemption from the school-vaccination requirement.
The families would then face decisions about compliance, homeschooling alternatives, closing or restructuring schools, continued penalties, or relocation.
The Court could require strict scrutiny
This would not automatically mean the Amish win.
It would require New York to prove that applying the mandate without a religious exemption is narrowly tailored to achieve a compelling governmental interest.
The state would almost certainly identify prevention of communicable disease as compelling.
The harder fight would concern whether refusing any religious accommodation is sufficiently narrow.
The Court could recognize a specific Amish parental-rights claim
A narrower ruling might focus on the combination of private religious schooling, longstanding Amish practice, and Yoder rather than creating a nationwide right to religious vaccine exemptions for everyone.
The Court could decline review
If the justices deny the next petition, the June 2026 Second Circuit ruling would remain controlling in the case.
That possibility is why the plaintiffs' reported relocation warnings have become more immediate.
Would an Amish Victory End School Vaccine Mandates?
Not necessarily.
This is important.
A Supreme Court victory for the plaintiffs could be narrow.
For example, the Court might determine that New York must provide an exemption under a specific constitutional test without questioning states' general authority to require vaccinations.
Alternatively, a broader ruling could change how states nationwide must treat religious objections when their laws include other exemptions.
The impact would depend entirely on the Court's reasoning.
School vaccination mandates themselves have more than a century of support in American constitutional law.
The unresolved question is increasingly about what exemptions the Constitution requires.
Would a New York Victory End Religious Vaccine Exemptions Nationwide?
No.
States can provide protections beyond the constitutional minimum.
Even if the Supreme Court held that the U.S. Constitution does not require New York to offer religious exemptions, another state could choose to offer them legislatively.
Pennsylvania currently does.
So do numerous other states.
The question in Miller is whether New York must provide an exemption—not whether every state is prohibited from providing one.
That distinction explains why relocation is a realistic legal alternative for families unwilling to vaccinate.
Crossing a state boundary can change the applicable school-immunization rules without changing the family's religious convictions.
Why This Case Is Bigger Than Vaccination
At its deepest level, Miller v. McDonald asks where parental authority ends when a family enters a regulated social environment.
Parents generally have substantial control over:
- religious upbringing;
- schooling choices;
- medical decisions;
- family life.
But parental authority has never been absolute.
States also regulate:
- compulsory education;
- child welfare;
- infectious disease;
- school safety;
- medical neglect;
- educational standards.
Most of the time, these spheres coexist without constitutional crisis.
The hard cases occur when a parent's religious obligation points in one direction and a generally applicable safety law points in another.
That is exactly what happened here.
Religious Liberty Does Not Automatically Decide the Case
Supporters of the Amish sometimes frame the case as though the First Amendment necessarily requires an exemption.
Legally, that remains disputed.
Religious freedom protects belief absolutely in ways that it does not always protect conduct from generally applicable regulation.
Courts have long recognized that government could not function if every religious objection automatically invalidated every law.
The Second Circuit explicitly relied on this principle when it again rejected the Amish challenge.
But the opposite simplification is also incomplete.
A government cannot merely call something a neutral regulation and automatically escape constitutional scrutiny if its exemptions, administration, or practical operation discriminate against religion.
Modern Supreme Court Free Exercise cases have strengthened protections where governments treat comparable secular activity more favorably.
That is why the medical-exemption question matters so much.
Public Health Does Not Automatically Decide It Either
Vaccination has a strong scientific public-health rationale.
That does not resolve every constitutional question.
American constitutional law regularly protects individual rights even when government policy serves legitimate purposes.
Courts therefore ask not only whether the government has a good objective but also:
- how the law is structured;
- whom it exempts;
- whether religion is treated equally;
- what burden is imposed;
- whether less restrictive alternatives exist;
- which level of judicial scrutiny applies.
The central legal disagreement is not whether preventing communicable disease is a legitimate interest.
It plainly is.
The disagreement concerns how far the state may go when accomplishing that interest collides with sincere religious practice.
Why Accuracy Matters in Reporting the Amish Vaccine Fight
This dispute sits at the intersection of religion, vaccines, politics, and parental rights—all subjects prone to exaggeration.
Several claims should therefore be separated carefully.
New York did eliminate its religious school-vaccine exemption in 2019.
That is documented.
Three Amish schools were fined a combined $118,000.
That is documented in the court record.
The Supreme Court vacated the first Second Circuit decision in December 2025.
That is documented in the Supreme Court docket.
The Second Circuit again ruled against the plaintiffs on June 30, 2026.
That is documented.
Their attorneys say they plan to return to the Supreme Court.
That has been publicly announced.
Reports say families may relocate if they ultimately lose.
That has also been reported.
What has not been established is that all roughly 26,000 Amish residents of New York have collectively committed to leave.
That distinction turns a sensational headline into a much more interesting story.
Why the "Amish vs Modern Medicine" Narrative Is Too Simple
The plaintiffs' religious objections deserve to be described accurately because courts themselves treat sincerity seriously.
But it is equally important not to transform three school communities into a stereotype about all Amish people.
Research demonstrates substantial variation in Amish health choices.
Some families vaccinate.
Some partially vaccinate.
Some decline vaccination.
Reasons can include:
- religious concerns;
- distrust of institutions;
- vaccine-safety concerns;
- local community norms;
- access issues;
- perceptions of disease risk.
The CDC has previously observed that Amish religious doctrine does not universally prohibit vaccination, even while documenting low immunization coverage and outbreaks in some Amish communities.
The New York plaintiffs may have sincere religious objections without those objections constituting a universal Amish doctrine.
Both facts can be true.
What Happens Next?
The most important development to watch is the promised new Supreme Court petition.
If filed, the case could force the justices to decide whether the Second Circuit interpreted Mahmoud correctly.
The legal question would arrive at a moment when the Court has shown strong interest in Free Exercise claims and parental religious rights.
But the state would arrive with more than a century of vaccination precedent and a well-documented public-health justification.
That makes Miller v. McDonald unusually difficult to predict.
It is not simply:
religion versus government.
Nor is it:
science versus faith.
It is a dispute over how constitutional government accommodates both.
The Bottom Line
New York's Amish vaccine dispute is real, but the most dramatic versions of the story need qualification.
In 2019, after a historic measles outbreak, New York eliminated religious exemptions from vaccination requirements for children attending public, private, and religious schools. Medical exemptions remained.
Three Amish community schools later refused to require vaccination because parents involved in the case say doing so violates sincerely held religious beliefs.
New York imposed $118,000 in fines.
The schools and Amish parents sued.
They lost in federal district court and initially lost in the Second Circuit.
The Supreme Court then vacated that appellate decision in December 2025 and instructed the court to reconsider the case after Mahmoud v. Taylor, a major parental religious-rights ruling.
On June 30, 2026, the Second Circuit again sided with New York.
It concluded that vaccination is a neutral, generally applicable health-and-safety requirement and that its burden on Amish families is legally different from the religious-education burdens considered in Wisconsin v. Yoder and Mahmoud.
The Amish plaintiffs' attorneys say they are going back to the Supreme Court.
If they ultimately lose, reports indicate that at least some affected families may choose relocation rather than vaccination.
Pennsylvania is an obvious possible destination because its school rules continue to recognize religious and strong moral or ethical exemptions.
But a statewide Amish departure has not yet been announced.
New York had an estimated 26,320 Amish residents in 2026 across 64 settlements, and those communities are not governed as one centralized organization.
The phrase "mass exodus" therefore describes a potential consequence, not an accomplished fact.
The more consequential question is what happens if the Supreme Court accepts the case again.
A ruling could clarify whether the strengthened parental religious rights recognized in recent Supreme Court decisions extend to vaccination requirements at private religious schools.
It could also determine how states must balance medical exemptions, disease prevention, parental authority, and sincere religious objections.
More than a century after the Supreme Court first approved governmental vaccination authority, and more than half a century after it protected Amish parents in Wisconsin v. Yoder, those two constitutional traditions may now be moving toward a direct confrontation.
Frequently Asked Questions
Are Amish families really threatening to leave New York over vaccines?
Attorneys and recent reports say some Amish families may relocate if they ultimately cannot operate their religious schools without complying with New York's vaccination mandate. However, there is no documented decision by New York's entire Amish population to leave the state.
How many Amish people live in New York?
The Young Center for Anabaptist and Pietist Studies estimated approximately 26,320 Amish residents in New York in 2026, living across 64 settlements and 198 church districts.
What is the New York Amish vaccine lawsuit called?
The case is Miller v. McDonald, involving Amish parents, Amish schools, and New York health officials.
Why are the Amish schools suing New York?
The plaintiffs argue that forcing their children to receive vaccinations as a condition of attending Amish community schools violates sincere religious beliefs and interferes with parents' ability to direct their children's religious upbringing.
When did New York eliminate religious vaccine exemptions?
New York eliminated nonmedical school-vaccination exemptions, including religious exemptions, on June 13, 2019.
Why did New York eliminate the religious exemption?
The repeal followed the 2018–2019 measles crisis. In 2019, the United States recorded 1,249 measles cases, with major prolonged outbreaks in undervaccinated New York communities.
Was the 2019 New York measles outbreak caused by the Amish?
The largest New York outbreaks were concentrated primarily in close-knit Orthodox Jewish communities, not Amish communities. The law enacted afterward applied statewide to all covered schools.
How much were the Amish schools fined?
Three plaintiff schools were fined a combined $118,000: $52,000 for Dygert Road School, $46,000 for Pleasant View/Twin Mountain School, and $20,000 for Shady Lane School.
Why are the fines so high?
New York law allows fines of up to $2,000 per violation, and the Department of Health can treat each day that an unvaccinated student improperly attends school as a separate violation.
Does New York allow any vaccine exemptions?
Yes. New York permits medical exemptions when vaccination is medically contraindicated for a particular child. It does not currently provide nonmedical religious exemptions for K–12 school attendance.
Why do Amish plaintiffs say a medical exemption makes the law unfair?
They argue that because New York accommodates some unvaccinated children for secular medical reasons, the state should also accommodate sincere religious objections. The Second Circuit rejected that comparison, reasoning that medical exemptions are tied to the law's health objective and are limited by documented contraindications.
Did the Supreme Court already rule that New York's mandate is unconstitutional?
No. In December 2025, the Supreme Court vacated the earlier Second Circuit judgment and remanded the case for reconsideration in light of Mahmoud v. Taylor. It did not issue a final merits ruling that New York must provide a religious vaccine exemption.
Why did the Second Circuit rule against the Amish again?
The court concluded in June 2026 that New York's vaccination law is neutral and generally applicable. It also held that requiring vaccination before school attendance is legally different from the direct interference with religious education considered in Yoder and Mahmoud.
What is Wisconsin v. Yoder?
Wisconsin v. Yoder is a 1972 Supreme Court decision protecting Amish parents from a state law requiring their children to continue formal schooling beyond eighth grade when doing so conflicted with their religious way of life.
Why is Wisconsin v. Yoder relevant to vaccines?
The New York Amish plaintiffs argue that their own schools are central to transmitting their religion and way of life, so forcing them to choose vaccination or loss of community schooling similarly interferes with religious child-rearing.
What is Mahmoud v. Taylor?
Mahmoud v. Taylor is a 2025 Supreme Court decision involving parents who objected on religious grounds to certain instructional materials in Maryland public schools without an opt-out. The Court ruled that the parents were entitled to preliminary relief and treated parental religious formation as a significant Free Exercise interest.
Is the Amish vaccine case going back to the Supreme Court?
Attorneys for the plaintiffs have publicly announced their intention to petition the Supreme Court again following the Second Circuit's June 30, 2026 decision.
Has the new Supreme Court petition already been decided?
No. The earlier Supreme Court case resulted in a December 2025 vacatur and remand. The latest Second Circuit decision was issued June 30, 2026, and counsel has announced plans for another petition.
Do all Amish people oppose vaccines?
No. Research shows substantial variation between Amish communities and families. Some vaccinate fully or partially, while others do not. Religious belief is only one of several factors associated with lower vaccination uptake.
Do the Amish reject all modern medicine?
No. Amish medical practices vary widely. Amish people use hospitals, physicians, surgery, medication, and other modern medical services in differing ways depending on family and community practices. It is inaccurate to characterize the entire Amish population as rejecting modern medicine.
Could the Amish move to Pennsylvania instead?
Yes, individual families or communities could relocate there, and Pennsylvania is particularly relevant because it has a large established Amish population and currently recognizes medical, religious, and strong moral or ethical exemptions from school immunization requirements.
Does Pennsylvania require vaccines for schoolchildren?
Yes. Pennsylvania has school vaccination requirements, but unlike New York it currently permits several exemptions, including religious exemptions.
Why does New York argue religious exemptions pose a health risk?
New York argues that allowing larger numbers of unvaccinated children to gather in schools increases the risk of vaccine-preventable disease transmission, including to people who cannot be vaccinated for medical reasons.
Are school vaccine mandates constitutional?
The Supreme Court has historically upheld significant state authority over vaccination and school attendance, including in Jacobson v. Massachusetts and Zucht v. King. Modern religious-liberty cases, however, continue to shape when constitutional exemptions may be required.
Can the government physically force Amish children to be vaccinated?
The current New York law operates primarily through conditions on school attendance and penalties for noncompliant schools rather than officials physically restraining children and administering vaccines. Families can refuse vaccination, but refusal affects legal eligibility for in-person school attendance under the statute.
What happens if the Amish win at the Supreme Court?
The result would depend on the scope of the ruling. The Court could require New York to accommodate these plaintiffs, apply strict scrutiny to the law, or issue a broader ruling affecting religious exemptions to vaccination requirements nationwide.
What happens if New York wins?
The vaccination requirement would remain enforceable against the plaintiff schools. Families unwilling to vaccinate would then have to consider legally permissible alternatives such as homeschooling, restructuring education, accepting applicable penalties, or moving to another state.
Would an Amish victory mean vaccines are unsafe?
No. A constitutional ruling about religious exemptions would address the limits of government authority and individual rights. It would not determine the scientific safety or effectiveness of vaccines.
Would a New York victory mean religious freedom does not matter?
No. It would mean the Court concluded that this particular neutral public-health requirement may constitutionally apply despite the religious burden. Religious liberty would continue to protect many other forms of belief and conduct.
Why is Miller v. McDonald nationally important?
The case could clarify how three major areas of constitutional law interact: religious freedom, parental authority over children's upbringing, and state power to prevent communicable disease. Because the Supreme Court has already sent the case back once, a second petition could become an important test of how far recent parental-rights decisions extend beyond school curriculum disputes.
Is a New York Amish mass exodus certain?
No. It is a possible consequence described by attorneys and affected families, not a completed or universally adopted plan. The outcome of further litigation—and how individual Amish communities respond—will determine whether relocation becomes widespread.