Jacobson v. Massachusetts Overview

Background

• Law Enactment: At the turn of the 20th century, Massachusetts allowed cities to enforce vaccination to protect public health.
• Penalty: Refusal to vaccinate resulted in a $5 fine.
• Case: Henning Jacobson refused vaccination and was fined; he appealed to the U.S. Supreme Court.
• Argument: Jacobson claimed the law violated the 14th Amendment's due process clause, calling it unreasonable and oppressive.

Supreme Court Decision

• Rejection of Jacobson's Position: The Court ruled that personal liberty is not absolute and can be restrained for public safety.
• State's Police Power: The law was seen as justified, but arbitrary use of power could compel court intervention.

Tests for Law Validity

1. Relation to Public Health/Safety: Does the statute have a real relation to public health, morals, or safety?
2. Invasion of Rights: Is the law a clear invasion of fundamental rights?

• These tests resemble later constitutional adjudication frameworks regarding means scrutiny and fundamental rights.

Jacobson's Legacy and Misinterpretation

• Modern Impact: Jacobson is still relevant in public health debates.
• Misinterpretation by Justice Holmes:
  • In Buck v. Bell, Holmes compared compulsory vaccination to sterilization.
  • Misunderstood Jacobson, as it did not support forced vaccination.
  • Jacobson allowed for fines, not forced medical procedures.
• Modern Understanding: Jacobson is a product of its time, and its principles are interpreted in the context of historical public health needs.