Caviezel v. Great Neck Public Schools, 500 F. App'x 16

Caviezels sought a religious exemption from New York’s vaccination requirement for public school attendance under N.Y. Pub. Health Law § 2164(7), (9).
District court denied preliminary injunctive relief, finding Caviezels failed to prove their religious beliefs against vaccination were genuine and sincere for purposes of a likelihood of success on the merits.
District court dismissed Caviezels’ First Amendment free exercise, Fourteenth Amendment equal protection and due process claims, and granted summary judgment on the state-law exemption claim under § 2164(9).
The district court’s credibility determinations were based on live witnesses at the preliminary injunction hearing, with evidence deemed inconsistent with Caviezels’ asserted beliefs.
Caviezels argued their right to counsel was chilled by the EDNY form requiring them to describe beliefs ‘in their own words,’ and that they were injured by the government’s actions regardless of outcome.
The Second Circuit reviews the district court’s rulings de novo for constitutional claims and for denial of injunctive relief, and reviews factual findings for clear error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court properly dismissed free exercise and equal protection claims.	Caviezel asserts sincere religious beliefs barred vaccination requirement.	District court credibility findings show no genuine, sincere beliefs; claims fail on merits.	Affirmed dismissal; credibility finding precludes viable free exercise and equal protection claims.
Whether the state immunization statute’s exemption claim survives after lack of First Amendment merit.	Exemption should be available due to religious beliefs opposing vaccines.	Jacobson-based authority allows vaccination mandates; exemption denied lawfully.	Affirmed; due to lack of viable free exercise claim, exemption denied under state law.
Whether Caviezels have standing to challenge the form’s ‘own words’ description requirement for beliefs.	Form chilling effect infringes due process and access to counsel.	Caviezels previously retained counsel and used it; no cognizable Article III injury.	Affirmed standing dismissal; no injury in fact from form requirement.
Whether the due process challenge is controlled by Jacobson v. Massachusetts.	Jacobson misreads individual liberty in vaccination decisions.	Jacobson controls; state power to prevent disease supports vaccination mandate.	Affirmed; Jacobson controls absence of viable due process challenge.

Mason v. Gen. Brown Cent. Sch. Dist., 851 F.2d 47 (2d Cir. 1988) (credibility of religious beliefs and equal protection implications)
Jacobson v. Massachusetts, 197 U.S. 11 (U.S. 1905) (state interest in preventing disease permits vaccine mandate)
Zucht v. King, 260 U.S. 174 (U.S. 1922) (supports public school inoculation requirement)
Cruzan ex rel. Cruzan v. Dir., Mo. Dep’t of Health, 497 U.S. 261 (U.S. 1990) (respect for liberty interests in medical treatment decisions)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S. 1992) (standing requirements; injury must be actual or imminent)
Rodriguez de Quijas v. Shearson/Am. Express, Inc., 490 U.S. 477 (U.S. 1989) (directs adherence to controlling Supreme Court precedent)