Zucht v. King

Background

A girl, Rosalyn Zucht, was excluded from a public school and from a private school in San Antonio because she did not present a required vaccination certificate and refused vaccination. City ordinances required proof of vaccination for attendance, and officials enforced that rule. Zucht sued the officials in state court seeking an injunction, a court order to force her admission to public school, and damages. The trial court dismissed her complaint; the state courts affirmed, and the case reached this Court on a writ of error granted by a lower appellate chief justice.

Reasoning

The Court examined whether the city law or its enforcement raised a substantial federal constitutional question under the Fourteenth Amendment. Citing earlier cases that upheld state authority to require vaccinations and to let cities set health rules, the Court found no substantial question about the ordinance’s validity. The bill’s separate allegation that officials had applied the rule in a discriminatory way did raise a constitutional concern, but the Court explained that such claims about wrongful administration of a valid ordinance are not properly reviewed on a writ of error and instead must be brought through a different petition process for review.

Real world impact

The Court dismissed the writ of error and did not grant federal review on the merits. The decision leaves in place the established view that cities may enforce vaccination rules and that disputes over discriminatory enforcement must be pursued through the appropriate petition route rather than by this procedural path.