Amicus Curiae Brief — Joseph Miller, et al., Petitioners v. James V. McDonald, Commissioner, New York State Department of Health, et al.

NO. 25-133

In the

Supreme Court of the United States

JOSEPH MILLER, ET AL.,

Petitioners,

v.

JAMES V. MCDONALD,

IN HIS OFFICIAL CAPACITY AS COMMISSIONER OF

HEALTH OF THE STATE OF NEW YORK, ET AL.,

Respondents.

__________________________

On Petition for a Writ of Certiorari to the

United States Court of Appeals for the Second Circuit

BRIEF OF AMICUS CURIAE

PHYSICIANS FOR INFORMED CONSENT

IN SUPPORT OF PETITIONERS

Gregory J. Glaser

Counsel of Record

4399 Buckboard Drive #423

Copperopolis, CA 95228

(925) 642-6651

greg@picphysicians.org

September 2, 2025

SUPREME COURT PRESS

Counsel for Amicus Curiae

♦

(888) 958-5705

♦

BOSTON, MASSACHUSETTS

i

TABLE OF CONTENTS

Page

TABLE OF AUTHORITIES ....................................... ii

IDENTITY AND INTEREST OF

THE AMICUS CURIAE ....................................... 1

SUMMARY OF ARGUMENT .................................... 2

ARGUMENT ............................................................... 2

A. Unequal Treatment of Religious and

Secular Vaccine Exemptions Is a

Recurring Legal Issue Splitting Decisions

in Lower Courts, and Causing Legislative

Confusion, for Decades..................................... 2

1. Ethical Reasons Support Petitioners.......... 5

2. Scientific Reasons Support Petitioners ...... 6

CONCLUSION.......................................................... 17

ii

TABLE OF AUTHORITIES

Page

TABLE OF AUTHORITIES

CASES

Bosarge v. Edney,

669 F. Supp. 3d 598 (S.D.Miss. 2023) ................. 2

Doescher v. Aragón,

No. 2:23-cv-02995-KJM-JDP 2025

U.S.Dist.LEXIS 47872

(E.D.Cal. Mar. 11, 2025) ..................................... 4

Gold v. Sandoval,

No. 3:21-cv-00480-JVS-CBL

(D.Nev. Dec. 3, 2021) ........................................... 3

Grimsby v. Pan,

No. 5:25-cv-01575-JFW

(C.D.Cal. Jun. 24, 2025) ...................................... 4

Kiel, et al. v. The Regents of the University of

California, et al., Case No. HG20072843

(Cal. Superior Ct., Alameda Cty.) ........................ 3

We the Patriots United States v. Conn. Office of

Early Childhood Dev.,

76 F.4th 130 (2d Cir. 2023) ................................. 3

STATUTES

Cal. Health & Safety Code § 120325 .......................... 1

Cal. Health & Safety Code § 120380 .......................... 1

JUDICIAL RULES

Sup. Ct. R. 37 .............................................................. 1

iii

TABLE OF AUTHORITIES – Continued

Page

OTHER AUTHORITIES

American Medical Association, AMA

Principles of Medical Ethics: I, II, V, VIII,

Informed Consent, (2025) https://www.

ama-assn.org/delivering-care/ethics/

informed-consent ................................................. 5

Conis, E.,

The History of the Personal Belief

Exemption, PEDIATRICS (2020)

Apr;145(4): e20192551. https://pubmed.

ncbi.nlm.nih.gov/32184337/ ................................ 1

Eli Y Adashi, I Glenn Cohen,

The CMS Vaccine Mandate at the

Supreme Court: A Hippocratic Imperative,

National Library of Medicine, (April 23,

2022) https://pmc.ncbi.nlm.nih.gov/

articles/PMC9033625/ ......................................... 4

Ethical Issues with Vaccination in Obstetrics

and Gynecology, Committee Opinion No.

829. American College of Obstetricians

and Gynecologists. Obstet Gynecol

2021;138:e16–23 (2021). https://www.

acog.org/clinical/clinical-guidance/

committee-opinion/articles/2021/07/

ethical-issues-with-vaccination-inobstetrics-and-gynecology ................................... 6

Physicians for Informed Consent,

Vaccines and the Diseases They Target:

An Analysis of Vaccine Safety and

Epidemiology, www.picdata.org/silverbooklet-federal ............... 7, 8, 9, 10, 11, 12, 13, 15

iv

TABLE OF AUTHORITIES – Continued

Page

Sean Golonka et al.,

GOP legislators block college student,

state worker vaccine mandate, THE DAILY

INDY, https://thenevadaindependent.com/

article/gop-legislators-block-collegestudent-state-worker-vaccine-mandate .............. 3

Sean Golonka, Jacob Solis,

GOP legislators block college student,

state worker vaccine mandate, The

Nevada Independent, (December 21,

2021) https://thenevadaindependent.com/

article/gop-legislators-block-collegestudent-state-worker-vaccine-mandate .............. 3

Zalman Rothschild,

Individualized Exemptions, Vaccine

Mandates, and the New Free Exercise

Clause, The Yale Law Journal,

(September 18, 2021) https://www.

yalelawjournal.org/forum/individualizedexemptions-vaccine-mandates-and-thenew-free-exercise-clause ..................................... 4

1

IDENTITY AND INTEREST

OF THE AMICUS CURIAE1

Pursuant to Supreme Court Rule 37, Amici

Curiae, submits this brief.

PHYSICIANS FOR INFORMED CONSENT (“PIC”), a

501(c)(3) nonprofit educational organization focused

on science and statistics. PIC delivers data on infectious

diseases and vaccines, and unites doctors, scientists,

healthcare professionals, attorneys, and families who

support voluntary vaccination. In addition, its Coalition

for Informed Consent consists of over 350 U.S. and

international organizations.

PIC was founded in California in 2015, by doctors,

scientists, and attorneys, after SB277 was signed into

law2 and their parental rights to personal belief and

religious exemptions from childhood vaccination for

both private and public school were usurped—even

though both of these rights had been protected since

1911.3

1 No counsel for a party authored this amicus brief in whole or

in part, and no person other than amicus, its members, or its

counsel made a monetary contribution to fund the production of

the brief. Both parties received timely notice of this filing.

2 Cal. Health & Safety Code §§ 120325–120380

3 Conis, E., The History of the Personal Belief Exemption,

PEDIATRICS (2020) Apr;145(4): e20192551. https://pubmed.ncbi.

nlm.nih.gov/32184337/

2

SUMMARY OF ARGUMENT

The lower court rulings should have applied

strict scrutiny because Respondents favored secular

exemptions while concurrently prohibiting religious

exemptions to vaccination. Courts are split on this

recurring legal issue. Ethical and scientific reasons

support Petitioners under the Equal Protection Clause.

ARGUMENT

A.

Unequal Treatment of Religious and

Secular Vaccine Exemptions Is a Recurring

Legal Issue Splitting Decisions in Lower

Courts, and Causing Legislative Confusion,

for Decades

For decades plaintiffs have challenged States’

unequal treatment of religious and secular exemptions

to vaccination. But in the last decade the split

decisions have created a constant current of lawsuits,

especially in California and New York. The fact

patterns in these cases have the same commonality:

a student is denied a religious exemption because of

a State law that respects only medical exemption.

The cases fit in three categories:

(1) Successful cases at trial where the court

ordered the defendant State agency to grant

the unvaccinated the same equal protection

afforded to the vaccinated (e.g., Bosarge v.

Edney (S.D.Miss. 2023) 669 F. Supp. 3d 598);

3

(2) Cases settled or dismissed favorably before

trial because the State agency changed

policy during the litigation to afford equal

protection to the unvaccinated (e.g., Gold v.

Sandoval (D.Nev. Dec. 3, 2021), No. 3:21-cv00480-JVS-CBL [legislative body ended

vaccine mandate after motion to dismiss

equal protection claim4]; and Kiel v. Regents

of the Univ. of California, 2020 Cal. Super.

LEXIS 46082 [university restored a religious

exemption after motion to dismiss equal

protection claim5]); and

(3) Unsuccessful cases where the court found the

unvaccinated need not be treated equally

with the vaccinated (e.g., We the Patriots

United States v. Conn. Office of Early

Childhood Dev. (2d Cir. 2023) 76 F.4th 130.)

In the instant Miller case, it appears the lower

courts (NY D.Ct and Second Circuit) assumed that

category (3) was the most prominent constitutional

outcome, but in reality (1) and (2) reach the same

constitutional outcome and are just as frequent,

emphasizing both the recurring split among courts

and dire need among lawyers for clarity in this area.

4 See news article announcing the legislative change and citing

the case. GOP legislators block college student, state worker vaccine

mandate, THE DAILY INDY, https://thenevadaindependent.com/

article/gop-legislators-block-college-student-state-workervaccine-mandate

5 See university’s executive order announcing change in policy

immediately after the lawsuit’s filing. https://childrenshealthdefense

.org/wp-content/uploads/sept29EO.pdf

4

For obvious reasons, category (2) cases are more

difficult to find on Lexis-Nexis or Westlaw, but their

abundant existence is known by the lawyers (such as

the undersigned) who have litigated in this area, especially in the last five years. We have observed a decisive

legal shift in favor of governments respecting religious

exemptions together with medical exemptions.6

And technically there is a fourth category (4):

equal protection cases in progress so the outcome is

unknown (e.g., Doescher v. Aragón (E.D.Cal. Mar. 11,

2025), No. 2:23-cv-02995-KJM-JDP) 2025 U.S.Dist.

LEXIS 47872 [currently on Ninth Circuit appeal];

and Grimsby v. Pan (C.D.Cal. Jun. 24, 2025), No.

5:25-cv-01575-JFW), which would all benefit from

SCOTUS resolving the recurring legal issue of how to

apply the equal protection clause to vaccinated and

unvaccinated children in a school attendance setting.

6 Indeed, the only vaccine mandate upheld by this Supreme

Court (a Medicare worker vaccine mandate in 2022) allowed for

religious exemptions. See e.g., https://pmc.ncbi.nlm.nih.gov/

articles/PMC9033625/ And further, since then legal commentators

have been almost uniformly waiting for this Supreme Court to

make explicit equal protection for the unvaccinated just like

this Court has done so in similar situations. Even aggressive

vaccine mandators recognize the Supreme Court’s current

jurisprudence requires equal protection for the unvaccinated.

See e.g., https://www.yalelawjournal.org/forum/individualizedexemptions-vaccine-mandates-and-the-new-free-exercise-clause

(“The free exercise vaccine-mandate cases demonstrate that the

Supreme Court’s new doctrine, couching free exercise as an

equality right, is far more protective of religious objectors than

was the Court’s previous doctrine framing free exercise as a

liberty right. Indeed, this new doctrine has already achieved

what was previously thought unfathomable: conferring upon

religious objectors the right of vaccine refusal.”)

5

Future court decisions are likely to continue

splitting over the Equal Protection Clause until

SCOTUS provides the needed clarity.

1. Ethical Reasons Support Petitioners

Universally recognized by physicians, informed

consent/refusal in vaccination is ethically the standard

of care. Banning religious exemptions to vaccination

effectively legalizes “medical bullying by proxy” by

allowing legislators to dictate the personal medical

care of families by threatening the loss of rights and

benefits (for children to attend school).

Informed consent to medical treatment is

fundamental in both ethics and law. Patients

have the right to receive information and ask

questions about recommended treatments so

that they can make well-considered decisions

about care. Successful communication in the

patient-physician relationship fosters trust

and supports shared decision making.

American Medical Association (2025). AMA Principles

of Medical Ethics: I, II, V, VIII, Informed Consent.

https://www.ama-assn.org/delivering-care/ethics/

informed-consent.

Informed consent is a core component of the

ethical clinical relationship. As with all

forms of medical therapy, informed consent

should precede vaccination administration.

. . . If the patient declines, this informed

refusal of recommended vaccination should

be respected . . . . Patients who decline

vaccination should continue to be supported

with appropriate care options that honor their

6

autonomous choices.

Ethical Issues with Vaccination in Obstetrics and

Gynecology. (2021) Committee Opinion No. 829.

American College of Obstetricians and Gynecologists.

Obstet Gynecol 2021;138:e16–23. https://www.acog.

org/clinical/clinical-guidance/committee-opinion/articles/

2021/07/ethical-issues-with-vaccination-in-obstetricsand-gynecology

Safeguarding informed consent/refusal is quite

essential to a successful doctor-patient relationship.

Vaccination carries risk of harm and is an invasive

medical procedure that punctures the skin for direct

access to the patient’s tissue and bloodstream. For a

state or federally-funded institution to engage in

coercing this medical procedure upon patients (by

threatening to strip their education) is unethical and

has been illegal for much of U.S. history unless exemptions were allowed. See footnote 3.

2. Scientific Reasons Support Petitioners

Americans are constantly in different stages of

learning about the benefits and risks of vaccination.

The Equal Protection Clause provides a vital safeguard for these interests. The scientific authorities

presented in the remainder of this amicus brief

emphasize that each childhood vaccine has not been

proven safer than the disease in normal-risk children

who are healthy enough to attend school.

At the district court, Petitioners introduced the

expert declaration of James Neuenschwander, MD

(D.Ct. Dkt. 28-4 (Aug. 25, 2023)), which provided a

trustworthy analysis (with rigorous citation to PubMed

.gov) of the scientific consensus among integrative

7

physicians regarding this subject of vaccine risk

versus disease risk.

The amicus analysis below is offered as further

support that Plaintiff’s expert Dr. Neuenschwander

is right that the State of New York cannot scientifically

defend its mandate under any level of scrutiny, least

of all strict scrutiny. In other words, the State of

New York, like the CDC, has not proven and cannot

prove that the vaccine is safer than the disease it

targets.

And this amicus would know, because it is the

very mission of our organization to know the answer

to this very narrow question: what are the exact

numbers comparing disease risk and vaccine risk?

We have found the question so vitally important that

we have spent the last 10 years pursuing it and

proving it by citation to mainstream sources only.

And this year our organization published our

rigorous scientific results: Vaccines and the Diseases

They Target: An Analysis of Vaccine Safety and

Epidemiology. www.picdata.org/silver-booklet-federal

(hereafter “Silver Booklet”).

In the Silver Booklet, our doctors group reached

the following conclusion, “For normal-risk U.S.

children the data is inconclusive. Vaccines may cause

more death or permanent disability than the

diseases they target. Therefore, it’s not accurate to

state that vaccines have been proven safer than

those diseases.”

Thus, if the lower courts had applied strict

scrutiny as Petitioners properly requested, then Dr.

Neuenschwander’s testimony at the District Court

(based on the vetted official sources) would definitively

8

require equal protection for the vaccinated and

unvaccinated.

a. What Do Parents and Guardians

Need to Know Regarding the Risk

of Polio Versus the Risk of the

Polio Vaccine?

The following are highlights of essential facts

from the Silver Booklet (pages 20-21) on polio:

●

Before the introduction of the polio vaccine

in 1955, paralytic poliomyelitis was a disease

of low incidence, occurring in about 1 in

22,000 or 0.005% in the U.S. population.

●

Before the polio vaccine was introduced,

about 0.0005% (1 in 190,000) of children at

normal risk contracted polio that was fatal

or led to permanent paralysis.

●

About 95% of people who contract polio have

no symptoms (asymptomatic).

●

The great majority of polio infections that

are fatal or result in permanent paralysis

occur in people who have had their tonsils

surgically removed (tonsillectomy) or do not

rest after feeling sick.

As a necessary comparison, highlights from the

Silver Booklet (pages 22-23) on the polio vaccine are

here:

●

The polio vaccine does not prevent asymptomatic infection or transmission.

●

The Institute of Medicine has not ruled out

the possibility that IPV vaccination can lead

9

to Guillain-Barré syndrome or sudden infant

death syndrome (SIDS).

●

Seizures may occur in about 1 in 829

children vaccinated with IPV vaccine.

●

A study published in the Journal of the

American Medical Association (JAMA) did

not rule out the possibility that an IPVcontaining vaccine may cause permanent

injury in 1 in 500 vaccinated people.

●

The polio vaccine has not been proven safer

than polio infection for normal-risk children.

b. What Do Parents and Guardians

Need to Know Regarding the Risks

of

Diphtheria,

Tetanus,

and

Pertussis Versus the Risks of the

DTaP Vaccines?

The following are highlights of PIC’s Silver

Booklet on diphtheria (pages 8-9), tetanus (pages 1011), and pertussis (pages 12-13):

●

In the modern era, it is rare to contract a fatal

case of diphtheria, tetanus or pertussis in

the United States.

●

Between 1900 and 1945, before widespread

use of the DTP vaccine, the mortality rate of

diphtheria, tetanus, and pertussis dropped

significantly (by 97%, 79% and 92% respectively) due to advancements in living conditions, sanitation, nutrition, and health care.

●

In the absence of mass vaccination, for

children under age 10, the annual risk of

fatal diphtheria, tetanus, and pertussis

10

respectively is 1 in 1.7 million (or 0.00006%),

1 in 784,000 (or 0.0001%), and 1 in 323,000

(or 0.0003%) — and the cumulative annual

risk of a fatal case of any of those diseases is

about 1 in 200,000 (or 0.0005%). (Silver

Booklet, page 14).

As necessary comparisons, highlights from PIC’s

Silver Booklet (pages 14-15) on the DTaP vaccine are

here:

●

DTaP is a descendant of the DTP vaccine,

which was introduced in 1948; it contains

aluminum, a neurotoxin.

●

The DTaP vaccine does not prevent asymptomatic infection or the spread of diphtheria

or pertussis, and it has no effect on the

transmission of tetanus because tetanus is

not contagious. The Institute of Medicine has

not ruled out the possibility that DTaP

vaccination can lead to neurological disorders

(e.g., encephalitis, infantile spasms, ataxia,

autism, transverse myelitis, optic neuritis,

multiple sclerosis, Guillain-Barré syndrome,

and Bell’s palsy), autoimmune diseases (e.g.,

chronic urticaria, serum sickness, and

arthropathy), myocarditis, and sudden infant

death syndrome.

●

The manufacturer’s package insert states that

the DTaP vaccine has “not been evaluated

for carcinogenic or mutagenic potential or

impairment of fertility.”

●

The DTaP vaccine has not been proven safer

than diphtheria, tetanus, and pertussis.

11

c. What Do Parents and Guardians

Need to Know About the Risks of

Chicken Pox (Varicella) Versus the

Risks of the Chicken Pox Vaccine?

The following are highlights from PIC’s Silver

Booklet (pages 32-33) on chicken pox:

●

More than 96% of new varicella infections

are benign and not reported to public health

departments.

●

Even before the introduction of the varicella

vaccination program, fatal cases of varicella

were already rare at a rate of 1 in 40,000 or

0.003% of varicella cases.

●

Because varicella infection resolves on its

own in almost all cases, usually only rest and

hydration are necessary.

●

Immune globulin is available to treat immunocompromised patients who are exposed to

chicken pox, such as those on chemotherapy.

As a necessary comparison, highlights from PIC’s

Silver Booklet (pages 34-35) on the chicken pox

vaccine are here:

●

The Centers for Disease Control and

Prevention (CDC) states, “It is not known

how long a vaccinated person is protected

against varicella.”

●

The Institute of Medicine has not ruled out

the possibility that varicella vaccination can

lead to stroke as well as several neurological and autoimmune disorders, including

encephalopathy, cerebellar ataxia, transverse

12

myelitis, Guillain-Barré syndrome, small

fiber neuropathy, arthropathy, and thrombocytopenia.

●

Seizures may occur in about 1 in 940 children

vaccinated with the varicella vaccine.

●

A study published in The Pediatric Infectious Disease Journal did not rule out the

possibility that the varicella vaccine may

cause permanent injury in 1 in 919 vaccinated people.

●

The chicken pox (varicella) vaccine has not

been proven safer than chicken pox.

d. What Do Parents and Guardians

Need to Know Regarding the Risks

of Hepatitis B Versus the Risks of

the Hepatitis B Vaccine?

The following are highlights from PIC’s Silver

Booklet (pages 4-5) about hepatitis B:

●

An unvaccinated normal-risk child has a 1 in

7,000,000 (or 0.00001%) chance of contracting

fatal hepatitis B annually.

●

About 50% of hepatitis B-vaccinated children

lose their immunity by age 5, and the vaccine

has not made a measurable impact on the

prevalence of chronic hepatitis B infection.

As a necessary comparison, highlights from PIC’s

Silver Booklet (pages 6-7) on the hepatitis B vaccine

are here:

●

Seizures may occur in about 1 in 1,300

children vaccinated with the hepatitis B

vaccine.

13

●

The hepatitis B vaccine contains an amount

of aluminum that is 75 times greater than

the maximum safe level of aluminum in the

bloodstream per day for a 7.3-pound infant.

●

The Institute of Medicine found that evidence

is inadequate to rule out the possibility that

hepatitis B vaccination leads to more than

two dozen neurological and autoimmune

disorders.

●

The hepatitis B vaccine has not been proven

safer than hepatitis B infection for normalrisk children.

e. What Do Parents and Guardians

Need to Know Regarding the Risks

of Measles, Mumps, and Rubella

Versus the Risks of the MMR

Vaccine?

The following are highlights from PIC’s Silver

Booklet (pages 24-25) on measles:

●

In 1963, before the measles vaccine was

introduced in the U.S., almost everyone had

measles by age 15, which provided lifelong

immunity. And measles was a generally

benign infection, with 99.99% of people

experiencing a full recovery.

As a necessary comparison, highlights from PIC’s

Silver Booklet (pages 30-31) on the MMR vaccine are

here:

●

Seizures from the MMR vaccine occur in

about 1 in 640 children within two weeks of

receiving the first dose of the MMR vaccine.

14

This amounts to approximately 5,700 cases

of MMR-vaccine seizures annually in the U.S.,

and a significant portion of MMR-vaccine

seizures may cause permanent harm, as 5%

of febrile seizures may result in epilepsy.

Consequently, about 300 MMR-vaccine

seizures (5% of 5,700) may lead to epilepsy

annually.

●

In 2007, the Centers for Disease Control and

Prevention (CDC) conducted a study on

waning immunity after two doses of the MMR

vaccine. the results, published in Archives of

Pediatrics and Adolescent Medicine, show

that even after being previously vaccinated

twice for measles, about 35% of vaccinated 7year-olds and 60% of vaccinated 15-year-olds

are susceptible to subclinical infection with

measles virus. And by age 24–26, a projected

33% of vaccinated adults are susceptible to

clinical infection. Consequently, nearly 50%

of schoolchildren and more than 60% of adults

fully vaccinated with the MMR vaccine can

still be infected with measles virus and

spread it to others, even with mild or no

symptoms of their own.

●

The CDC conducted another study in 2016,

published in The Journal of Infectious

Diseases, which concludes that a third dose

(booster shot) of the MMR vaccine is shortlived, lasting only one year. The authors state:

“MMR3 [a third dose of MMR] is unlikely to

solve the problem of waning immunity in the

United States . . . We did not find compelling

15

data to support a routine third dose of MMR

vaccine.”

f. What Do Parents and Guardians

Need to Know About the Risks of

Aluminum in Vaccines?

In the Silver Booklet (pages 38-40), PIC provides

the public with an Aluminum Vaccine Risk Statement

titled “Aluminum in Vaccines: What Parents Need to

Know.” The Booklet explains that both the FDA and

ATSDR have raised concerns about the negative

effects of aluminum exposure in humans. Scientific

studies have shown that small amounts of aluminum

can interfere with cellular and metabolic processes in

the nervous system. Some of the most damaging

effects of aluminum range from motor skill impairment

to encephalopathy (altered mental state, personality

changes, difficulty thinking, loss of memory, seizures,

coma, and more).

Studies have also shown that adverse effects of

aluminum may not be restricted to neurological

conditions. In 2008, the Agency for Toxic Substances

and Disease Registry (ATSDR), a division of HHS,

used studies of the neurotoxic effects of aluminum to

determine that no more than 1 milligram (mg) (1,000

micrograms [mcg]) of aluminum per kilogram (kg) of

body weight should be taken orally per day to avoid

aluminum’s negative effects.

Another study referenced in the Silver Booklet

and published in Academic Pediatrics found that

asthma occurred in 1 in 183 vaccinated children for

every 1 mg (1,000 mcg) increase in aluminum exposure.

In the United States, up to 22 doses of aluminum-

16

containing vaccines are administered to children, with

11 doses administered from birth to 6 months of age.

g. The Idea of ‘Under-Vaccination’ in

New York or Any Other State Is a

False Concept

Under-vaccination is not an ethical, legal, scientific, or medical concept. It is a politically motivated

false concept which distracts focus from the main

issues at hand, namely the 1) rights of individuals to

informed consent and refusal of medical procedures,

without penalties for choices which are unpopular in

the current political climate, and the 2) rights of

individuals to safeguard their children’s health, without

penalties for choices which are unpopular in the

current political climate.

The history of vaccine mandates is inseparable

from strife over these inalienable rights, and vaccine

mandates have only been allowed to enjoy a peaceful

existence when political compromise has respected

both secular and religious exemptions. See footnote 3.

17

CONCLUSION

Proper application of the Equal Protection Clause

is necessary to resolve the split among lower courts.

Petitioners should retain the right and dignity of

informed consent/refusal without penalty. The scientific

data currently available demonstrate that vaccines

mandated for school attendance have not been proven

safer than the infections they were designed to prevent.

Respectfully submitted,

Gregory J. Glaser

Counsel of Record

4399 Buckboard Drive #423

Copperopolis, CA 95228

(925) 642-6651

greg@picphysicians.org

Counsel for Amicus Curiae

Physicians for Informed Consent

September 2, 2025