B.W.C. v. Randall Williams, 990 F.3d 614

Parents/children in Missouri public schools sought religious exemptions from mandatory school immunizations but refused to sign the state-prescribed Form Imm.P.11A (Form 11) because it contains a DHSS pro-immunization message.
Form 11 combines a DHSS informational message urging vaccination with a separate parental election and checklist identifying which vaccines are objected to on religious grounds.
Some students (the Bakers) were disenrolled from school for failing to file Form 11, which Missouri law requires to document exemptions for school attendance.
Plaintiffs sued under 42 U.S.C. § 1983, alleging violations of free speech (compelled speech), free exercise of religion, equal protection (targeting religion), and a hybrid-rights theory; district court dismissed all claims.
The Eighth Circuit reviewed the dismissal de novo and affirmed, holding Form 11 and related procedures do not violate the First or Fourteenth Amendments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) Free speech / compelled speech	Form 11 forces parents to adopt or endorse DHSS’s pro-vaccine message when submitting the exemption.	Form 11 separates the government message from the opt-out; it does not compel affiliation or endorsement and allows other statements.	No compelled speech; form is the government’s own message and does not force parental endorsement.
2) Free exercise of religion	Signing Form 11 makes plaintiffs morally complicit in vaccination or its production, burdening their beliefs.	Form 11 is a neutral, generally applicable informational requirement that does not force vaccination or increase vaccine production.	No free-exercise violation; submission does not substantially burden religion.
3) Equal protection / targeting religion	The form and enforcement target religious objectors and deny them equal treatment.	The rule applies equally to all parents seeking exemptions; no discriminatory targeting.	No equal-protection violation; law is neutral in application.
4) Hybrid-rights / strict scrutiny	Combination of rights (speech + religion + others) triggers strict scrutiny.	Each individual claim fails on the merits; plaintiffs do not allege the kind of hybrid situation that warrants strict scrutiny.	No viable hybrid-rights claim; strict scrutiny not triggered and dismissal affirmed.

West Virginia Bd. of Ed. v. Barnette, 319 U.S. 624 (1943) (government may not force citizens to express orthodoxy).
Wooley v. Maynard, 430 U.S. 705 (1977) (state may not compel individuals to display an ideological motto).
Rumsfeld v. Forum for Acad. & Institutional Rights, Inc., 547 U.S. 47 (2006) (government cannot compel speech but may express its own views).
Hurley v. Irish-Am. Gay, Lesbian & Bisexual Grp. of Bos., 515 U.S. 557 (1995) (speakers can tailor expressive messages and decline forced attribution).
Turner Broad. Sys., Inc. v. FCC, 512 U.S. 622 (1994) (intermediate scrutiny for regulations that make speakers conduits for government message).
Employment Div., Dept. of Human Resources v. Smith, 494 U.S. 872 (1990) (neutral, generally applicable laws do not violate free exercise).
Little Sisters of the Poor Saints Peter & Paul Home v. Pennsylvania, 140 S. Ct. 2367 (2020) (a form that triggers third-party conduct can create a religious-objection burden).
Planned Parenthood v. Rounds, 530 F.3d 724 (8th Cir. 2008) (state may require truthful, nonmisleading information even if it encourages a particular choice).
Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520 (1993) (laws targeting religion require strict scrutiny).
Espinoza v. Montana Dep’t of Revenue, 140 S. Ct. 2246 (2020) (disqualifying beneficiaries solely for religious status triggers strict scrutiny).