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Zucht v. King
Citations: 260 U.S. 174; 43 S. Ct. 24; 67 L. Ed. 194; 1922 U.S. LEXIS 2356Docket: 84
Court: Supreme Court of the United States; November 13, 1922; Federal Supreme Court; Federal Appellate Court
Ordinances in San Antonio, Texas, mandated that individuals, including children, present vaccination certificates to attend public or private schools. Rosalyn Zucht was excluded from school due to her lack of such a certificate and refusal to be vaccinated, prompting her to file a lawsuit against the public officials. She claimed that the ordinances effectively made vaccination compulsory, violated her due process rights, and were void due to the lack of clear guidelines for their enforcement by the board of health, raising concerns about potential discrimination and abuse of power. Zucht sought an injunction against the ordinances, a writ of mandamus for school admission, and damages. The trial court dismissed her complaint, affirming that the ordinances did not violate the Fourteenth Amendment's due process and equal protection clauses. The Supreme Court of the United States acknowledged the validity of state police powers to mandate vaccinations, referencing prior rulings such as Jacobson v. Massachusetts, which confirmed that states could enforce compulsory vaccination laws. The court also noted that municipalities could be granted discretion in implementing health regulations, and that reasonable classification in regulation does not breach the equal protection clause, even if it is not universally applicable. Consequently, the court declined to assert jurisdiction over the case, determining that the constitutional questions were insubstantial. In Adams v. Milwaukee, the court determined that there is no substantial question regarding the validity of the ordinance that would support a writ of error. The ordinances in question do not grant arbitrary power but rather the necessary discretion to safeguard public health. Although the plaintiff alleged discrimination in the enforcement of the ordinance, which raises a significant constitutional issue, it does not pertain to the ordinance's validity or the officials' authority. This type of claim, which involves alleged unconstitutional application of a valid ordinance, can only be reviewed by the court through a petition for a writ of certiorari, not by writ of error. Consequently, the writ of error was dismissed.