Care and Protection of Eve., 258 N.E.3d 329

Background

The Department of Children and Families (DCF) took temporary custody of a newborn, "Eve," due to domestic violence concerns involving her parents.
Eve’s parents, practicing Rastafarians, objected to her routine vaccination on religious grounds and sought to bar DCF from vaccinating her while she was in temporary custody.
The parents noted that DCF had not vaccinated their three older children, who were also in the department's permanent custody.
The Juvenile Court judge allowed DCF’s motion to vaccinate the child, deciding the child’s best interests outweighed the parents’ religious claims; the parents appealed.
The Supreme Judicial Court granted direct appellate review after interlocutory review and denied stays at the lower court and Appeals Court levels.
Several vaccinations had already been administered to the child by the time of this appeal, but the department planned to continue vaccination per schedule.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can DCF vaccinate a child temporarily in its custody over parents’ religious objections?	Parents retain constitutional rights over their child's religious upbringing, even after temporary loss of custody; State allows religious exemptions for parents with custody.	DCF has authority to provide routine medical care, including vaccinations, and vaccinations serve the best interests and public health.	No; DCF must show that exempting the child would substantially hinder compelling interests; religious exemption allowed here.
Are the parents’ religious beliefs sincerely held?	Sincerely held Rastafarian belief prohibits vaccination.	Questioned sincerity due to inconsistencies in parents' actions.	Sincerity presumed; religious belief accepted as genuine for the purpose of analysis.
Does vaccinating the child substantially burden free exercise rights?	Vaccination is contrary to their sincerely held religious beliefs.	State interests outweigh the burden on religious exercise.	Yes, vaccinating contrary to parents’ wishes is a substantial burden on their free exercise rights.
Has DCF shown allowing an exemption would substantially hinder its goals?	Since the state allows religious exemptions and DCF hasn’t vaccinated other siblings, no substantial hindrance is shown.	Routine vaccination is necessary to protect child and public health.	No; DCF did not prove exemption would substantially hinder its mission, especially given policy inconsistencies.

Key Cases Cited

Prince v. Massachusetts, 321 U.S. 158 (Parental rights to religious upbringing of children are not absolute and can be restricted for child welfare.)
Meyer v. Nebraska, 262 U.S. 390 (Recognizes fundamental liberty interest of parents in upbringing of children.)
Santosky v. Kramer, 455 U.S. 745 (Temporary loss of custody does not extinguish fundamental parental rights.)
Wisconsin v. Yoder, 406 U.S. 205 (State power must respect parental religious upbringing rights, especially when linked to free exercise.)
Attorney Gen. v. Desilets, 418 Mass. 316 (Sets out Massachusetts standard for balancing state interests against free exercise rights.)
McCauley, 409 Mass. 134 (State can override parental religious objections only in extraordinary medical circumstances.)
Care & Protection of Jaylen, 493 Mass. 798 (Recognizes constitutional protection for parental decision-making regarding children.)
Custody of a Minor, 375 Mass. 733 (Confirms parental rights to raise children according to the dictates of conscience.)
Dalli v. Board of Educ., 358 Mass. 753 (Describes statutory vaccination exemptions as a deferential and minimally hazardous accommodation to religious belief.)
Society of Jesus of New England v. Commonwealth, 441 Mass. 662 (Compelling interests must be evaluated pragmatically and exemptions may be warranted.)
Rasheed v. Commissioner of Correction, 446 Mass. 463 (Articulates scope of religious freedom protections under Massachusetts Constitution.)
Magazu v. Dep't of Children & Families, 473 Mass. 430 (State constitutional protection of free exercise is broader than federal standard.)