Jacobson v. Massachusetts

Henning Jacobson, 1878

Jacobson v. Massachusetts was a landmark decision by the United States Supreme Court that was delivered in 1905. This case addressed the authority of states to enforce compulsory vaccination laws. The Supreme Court upheld the authority of states under the Tenth Amendment to the United States Constitution to pass and enforce such laws as a part of their police power. The case was brought forth by Henning Jacobson, a Swedish immigrant living in Cambridge, Massachusetts, who refused to comply with a smallpox vaccination mandate.

Background

In the late 19th and early 20th centuries, smallpox was a significant public health concern. In response, many states and municipalities enacted vaccination laws to control the spread of the disease. In 1902, in response to a smallpox outbreak, the Board of Health of Cambridge, Massachusetts, required all adults to be vaccinated against smallpox. Henning Jacobson, who had experienced an adverse reaction to a vaccine in his childhood in Sweden, refused to be vaccinated or pay the fine imposed for noncompliance. He argued that the law was an unreasonable, arbitrary, and oppressive invasion of his personal liberty and bodily autonomy under the Fourteenth Amendment.

Supreme Court Decision

The Supreme Court, in a 7-2 decision, held that the Massachusetts vaccination law was a reasonable regulation to protect the public health and safety and did not violate the Fourteenth Amendment. Justice John Marshall Harlan delivered the opinion of the Court. He argued that the liberty secured by the Constitution does not import an absolute right in each person to be, at all times and in all circumstances, wholly freed from restraint. Instead, liberty must be understood in the context of the restraint necessary for the common good.

The Court recognized the state's police power to regulate health and safety issues, including vaccination, as long as the regulations were not arbitrary or oppressive. In determining what is reasonable, the Court deferred to the legislature and local health authorities, presuming their actions were undertaken in good faith and in the best interests of the public.

Impact and Legacy

Jacobson v. Massachusetts has had a lasting impact on public health law and the scope of state power in the United States. It established the principle that states have the authority to enact and enforce laws for the protection of public health, even when those laws infringe on individual liberties, provided that the laws are reasonable and not arbitrary.

The decision has been cited in numerous subsequent cases concerning the limits of state power and individual rights, especially in the context of public health emergencies. It remains a foundational case in the field of public health law and is frequently referenced in debates over compulsory vaccination, quarantine measures, and other public health interventions.

See Also

• Police power (United States constitutional law)
• Public health law
• Compulsory vaccination
• Fourteenth Amendment to the United States Constitution