Zucht v King

Zucht v. King (1922) was a landmark U.S. Supreme Court case that upheld the authority of local governments to enforce school vaccination requirements, even in the absence of a current disease outbreak.

Background:

• The case originated in San Antonio, Texas, where Rosalyn Zucht, a student, was excluded from both public and private schools for failing to present a vaccination certificate
• Her family sued, arguing that the ordinance mandating vaccination violated her 14th Amendment rights (due process and equal protection)

Legal Question:

• Did the San Antonio ordinance requiring vaccination certificates for school attendance violate constitutional rights?

Supreme Court Decision:

• Unanimous decision delivered by Justice Louis Brandeis
• The Court ruled that:
  • The ordinance did not violate due process
  • Vaccination mandates for school entry were a legitimate exercise of a city’s police powers
  • Previous precedent - Jacobson v. Massachusetts (1905), which upheld compulsory vaccination, was reaffirmed

Significance:

• Confirmed that vaccine mandates could be preemptive, not just reactionary to outbreaks
• Set a precedent for public health policies in educational settings
• Reinforced the idea that individual liberties can be limited for the protection of public health
• Zucht v. King remains foundational in the legal justification for school vaccination requirements across the U.S

Core Holding:

The Court upheld the constitutionality of a San Antonio, Texas ordinance requiring children to show proof of vaccination to attend school, stating that:

"Long before this suit was instituted, Jacobson v. Massachusetts had settled that it is within the police power of a state to provide for compulsory vaccination."

This ruling affirmed that public schools could lawfully exclude unvaccinated students, even when there was no immediate outbreak, strengthening the legal foundation for preventative vaccine mandates in schools.