Jacobson v Massachusetts

The 1905 Supreme Court case Jacobson v. Massachusetts, 197 U.S. 11 (1905), is a landmark decision that upheld the authority of states to enforce compulsory vaccination laws under their police powers to protect public health.

Timeline of Events in Jacobson v. Massachusetts:

Late 1800s – Early 1900s:

• Smallpox outbreaks were occurring across the United States, including in Massachusetts

• Massachusetts passed laws allowing local boards of health to mandate smallpox vaccinations when necessary

1902:

• The Cambridge Board of Health ordered mandatory smallpox vaccinations for all residents, citing an outbreak

• Henning Jacobson, a Swedish-born pastor living in Cambridge, refused the smallpox vaccine, claiming he and his son had adverse reactions to previous vaccinations

Jacobson's Argument:

• He argued the mandate violated his Fourteenth Amendment rights to liberty and bodily integrity

• He was fined $5 (about $150 today) for refusing to comply and challenged the fine in court

1902–1904:

• Jacobson appealed through Massachusetts courts but lost at each level

February 20, 1905:

• The case was argued before the U.S. Supreme Court

February 27, 1905:

• The Court issued its decision, ruling 7–2 in favor of Massachusetts

Key Points from the Supreme Court Decision:

• Police Powers: The Court affirmed that states have broad authority under their "police powers" to enact laws that protect public health and safety

• Individual Rights vs. Public Good: The Court held that individual liberty is not absolute and can be curtailed when necessary to protect the public

• Judicial Deference: The Court deferred to the judgment of public health authorities, noting courts are not equipped to second-guess scientific decisions made by legislatures

• Not Absolute: The Court acknowledged there could be exceptions—such as individuals for whom vaccination would be dangerous—but Jacobson had not demonstrated such an exception

Impact of Jacobson v. Massachusetts

• The case has been a cornerstone precedent for public health law in the U.S., especially during health emergencies

• It has been cited in legal battles over vaccine mandates, quarantine enforcement, and COVID-19 measures

• However, courts since then have emphasized that Jacobson must be balanced with modern interpretations of constitutional rights