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Published online by Cambridge University Press: 24 March 2025
This essay reflects upon the last thirty-five years of public health law. Part One begins by discussing the growth and maturation of the field of public health law since the 1980s. Part Two examines current challenges facing public health law, focusing on those posed by the conservative legal movement and a judiciary that is increasingly skeptical of efforts to use law to improve health and mitigate health inequities. Part Three discusses potential responses to the increasingly perilous judicial climate, including thoughts that emerged from a convening held on the subject by the Act for Public Health Partnership in May 2024.
Matthews University Distinguished Prof. of Law, Northeastern University. Many thanks to Linda Tvrdy and Scott Burris for their helpful comments and Alison White and Margaret Babikian for their excellent research assistance. All errors are my own.
1 John A. Norris, Foreword, 1 Am. J.L. & Med. vii (1975).
2 Id.
3 Center for Disease Control and Prevention, First Report of AIDS, 60 Morbidity & Mortality Weekly Rpt. 429 (2001).
4 Lawrence O. Gostin, The Future of Public Health, 12 Am. J.L. & Med. 461, 461 (1986).
6 Wendy E. Parmet, Health Care and the Constitution: Public Health and the Role of the State in the Framing Era, 20 Hastings Constitutional L. Quarterly 267, 286-302 (1993).
7 See generally William J. Novak, The People’s Welfare: Law and Regulation in Nineteenth Century America (1996); see also Wendy E. Parmet, Constitutional Contagion: COVID, the Courts and Public Health 30-31 (2023).
9 James A. Tobey, Public Health Law: A Manual of Law for Sanitarians (1926).
10 Leroy Parker and Robert H. Worthington, The Law of Public Health and Safety and the Powers and Duties of Boards of Health (1892).
11 Parmet, supra note 7, at 34.
12 But see, e.g., Frank Grad, Public Health Law Manual: A Handbook on the Legal Aspect of Public Health Administration and Enforcement (1965).
13 Ed Yong, How Public Health Took Part in Its Own Downfall, The Atlantic (Oct. 23, 2021), https://www.theatlantic.com/health/archive/2021/10/how-public-health-took-part-its-own-downfall/620457/.
14 E.g., Theodore Ruger, Health Law’s Coherence Anxiety, 96 Geo. L.J. 625 (2008); Wendy K. Mariner, Toward an Architecture of Health Law, 35 Am. J.L. & Med. 67 (2009); Einer R. Elhauge, Can Health Law Become A Coherent Field Of Law? 41 Wake Forest L. Rev. 365 (2006).
15 The frequent presence of public health law topics in health law journals, including the American Journal of Public Health, and at health law conferences attests to the relationship between public health law and health law. From my own experience, almost all public health law scholars also publish and teach in other areas of health law.
16 Micah Berman, Defining the Field of Public Health Law, 15 DePaul J. Health Care L. 45, 52 (2013). In analyzing whether health law is a field, Berman draws upon Aagaard’s discussion of whether environmental law is a field. See Todd S. Aagaard, Environmental Law as a Legal Field: An Inquiry in Legal Taxonomy, 95 Cornell L. Rev. 221 (2010).
17 Wendy E. Parmet, From Deference to Indifference: Judicial Review of the Scope of Public Health Authority During the COVID-19 Pandemic, 17 St. L.J. Health L. & Pol’y 11-12 (2024).
18 See, e.g., Lawrence O. Gostin & Lindsay F. Wiley, Public Health Law: Power, Duty, Restraint (3d ed. 2016); Berman, supra note 16, at 80.
19 Berman, supra note 16, at 76.
20 Wendy E. Parmet, Populations, Public Health, and the Law 14 (2009).
21 Id. at 53-59.
22 Scott Burris, What is A Public Health Lawyer Today? Acting for, Against, and Beyond Public Health, 17 St. Louis. U. J. Health L. & Pol’y 113, 125 (2024).
23 Parmet, supra note 20, at 56.
24 Gostin & Wiley, supra note 18, at 4.
25 Burris, supra note 22, at 115.
26 Burris and colleagues advocate what they call a “transdisciplinary model” for public health law, in which lawyers “embrace and become competent in the language, concepts, and frameworks of public health science and tune their work to its scientific value,” and public health practitioners “accept law as a mode of behavioral and environmental influence that can be scientifically theorized, measured, and manipulated like any other.” Scott Burris et al., A Transdisciplinary Approach to Public Health Law: The Emerging Practice of Legal Epidemiology, 37 Ann. Rev. Pub. Health 135, 140-41 (2016).
28 Burris et al., supra note 26, at 139.
29 Centers for Disease Control and Prevention, About the Public Health Law Program (May 15, 2024), https://www.cdc.gov/phlp/php/about/index.html [https://perma.cc/T3KM-8DP5].
30 Robert Wood Johnson Found., https://www.rwjf.org/ (last visited Sept. 17, 2024).
31 James G. Hodge, Jr., Emergency Legal Preparedness and Response: A Decade of Unprecedented Challenges, The Network for Public Health Law, (Mar. 30, 2021), https://www.networkforphl.org/news-insights/emergency-legal-preparedness-and-response-a-decade-of-unprecedented-challenges/.
32 What We Do, The Network for Public Health Law, https://www.networkforphl.org/about-us/what-we-do/ (last visited July 25, 2024).
33 ChangeLab Solutions, Who We Are, https://www.changelabsolutions.org/who-we-are (last visited July 25, 2024).
34 Ctr. for Pub. Health L. Rsch., https://phlr.org/ (last visited Aug. 16, 2024).
35 Public Health Law Center at Mitchell Hamline School of Law, https://www.publichealthlawcenter.org/ (last accessed July 25, 2024).
36 Public Health Law Watch, https://www.publichealthlawwatch.org/ (last accessed July 25, 2024).
37 Act for Public Health, Support and Resources for Strengthening Public Health Protections, https://actforpublichealth.org/ (last accessed July 25, 2024).
38 See Alexis Etow & Rebecca Johnson, Opportunities in Public Health Law: Supporting Current and Future Practitioners, 52 J. L. Med. & Ethics 35 (2023).
39 Scott Burris et al., Better Health Faster: The 5 Essential Public Health Law Services, 131 Pub. Health Rpts. 747, https://journals.sagepub.com/doi/10.1177/0033354916667496.
40 Academic Program Finder, Ass’n of Schs. & Programs of Pub. Health, https://programfinder.aspph.org/ (last visited Sept. 17, 2024).
41 Gostin & Wiley, supra note 18.
42 See Burris, supra note 22, at 120 n.30.
43 Berman, supra note 16, at 90.
44 For a list of scholarly papers published in one journal alone, see James G. Hodge Jr., Reminiscences of Public Health Law and JLME, 50 J.L. Med. & Ethics 190, 191-92 (2022).
45 Berman, supra note 16, at 46-47.
46 Id.
47 Wendy E. Parmet & Richard A. Daynard, The New Public Health Litigation, 21 Ann. Rev. Pub. Health 437, 441-43 (2000).
48 Berman, supra note 16, at 46.
49 See Figure 1.
50 About the George Consortium, Pub. Health L. Watch, https://www.publichealthlawwatch.org/about-gc (last visited August 3, 2024).
51 Pub. Health L. Watch, https://www.publichealthlawwatch.org/ (last visited August 3, 2024).
52 Burris, supra note 22, at 120.
53 Apologies to all of the great scholars whose works I have not mentioned.
54 Cardiovascular Disease Data, Tools, and Evaluation Resources: Legal Epidemiology, https://www.cdc.gov/cardiovascular-resources/php/toolkit/legal-epidemiology.html. (See also Legal Epidemiology: Theory and Methods (Alexander C. Wagenaar et al eds., 2d ed. 2023).
55 As associate editor for law and ethics for the American Journal of Public Health, I can attest that the vast majority of submissions to the journal relating to law either embrace legal epidemiology explicitly or shows its footprints implicitly.
57 Burris notes this move, while criticizing the field for talking about it more than acting upon it. See Burris, supra note 22, at 135.
58 Feminist Judgements: Health Law Rewritten (Seema Mohapatra & Lindsay F. Wiley eds., 2022).
59 Ruqaiijah Yearby, Structural Racism and Health Disparities: Reconfiguring the Social Determinants of Health Framework to Include the Root Cause, 48 J.L. Med. & Ethics 518, 521 (2020).
60 E.g., Brian A. Smith et al., Public Health Law in the 21st Century: Evolution, Emerging Issues, and Equity, 65 How. L.J. 353, 374-83 (2022).
61 Centers for Disease Control and Prevention, Ten Great Public Health Achievements — United States, 2001–2010, 60 Morbidity & Mortality Weekly Rpt. 619-623 (May 20, 2011), https://www.cdc.gov/mmwr/preview/mmwrhtml/mm6019a5.htm [https://perma.cc/N54S-CTZY].
62 E.g., Christopher J. Ruhm, US State Restrictions and Excess COVID-19 Pandemic Deaths, 5 Jama Health Forum e242006 (2024) Beyond the stay-at-home orders and mandates, law played an important role in developing and disseminating vaccines and medical countermeasures, blunting the pandemic’s economic consequences, and supporting the health care system. Indeed, it is hard to point to any pandemic interventions that did not, to some extent, rely on law. See COVID-19 Policy Playbook: Legal Recommendations for a Safer, More Equitable Future (Scott Burris et al., eds. 2021).
63 See, e.g., Neil Fulton, COVID, Constitution, Individualism, and Death, 27 Widener L. Rev. 123, 133, 139-48 (2021); David A. Super, Community, Society, and Individualism in Constitutional Law, 111 Geo. L.J. 761, 761 (2023).
64 As far back as 1971, Lewis F. Powell, before he was appointed to the Supreme Court, argued that business interests were under attack and should organize to assert their influence in the courts. See Lewis F. Powell, The Memo, Powell Memorandum Attack on American Free Enterprise, Lewis F. Powell Papers, Aug. 23, 1971.
65 Lindsay F. Wiley, Wendy E. Parmet & Peter Jacobson, Adventures in Nannydom: Reclaiming Collective Action for the Public’s Health, 43 J.L. Med. & Ethics 73, 73 (Supp. Spring 2015).
66 See Amanda Hollis-Brusky, Ideas with Consequences: The Federalist Society and the Conservative Counterrevolution (2014). See also David Daley, The OTHER Memo That Started the Conservative Legal Movement, The Atlantic (July 30, 2024), https://www.theatlantic.com/ideas/archive/2024/07/michael-j-horowitz-report-1980/679236/. See also Sabrina Adler, Sara Bartel & Heather Wong, Authority to Improve or Harm Health: The Public Health Front in a Decades-Long Battle Over Governmental Powers, 17 St. L. U. J. Health L. & Pol’y 35, 38-39 (2024).
67 Adler, Bartel & Wong, supra note 66, at 40-48; See also Jennifer L. Pomeranz et al., State Preemption: Threat to Democracy, Essential Regulation, and Public Health, 109 Am. J. PUB. Health, 251-52 (2019).
68 Sabrina Adler et al., The (Un?)intended Consequences Of COVID-19-Era Judicial Decisions And New Public Health-Related Laws, Health Affs., (May 23, 2024) https://www.healthaffairs.org/content/forefront/un-intended-consequences-covid-19-era-judicial-decisions-and-new-public-health-related.
69 Darlene Huang Briggs, Elizabeth Platt & Leslie Zellers, Recent State Legislative Attempts to Restructure Public Health Authority: The Good, The Bad, and The Way Forward, 52 J.L. Med. & Ethics 43 (2023); Robert Gatter, The Model Public-Health Emergency Authority Act, 17 St. L. Univ. J. Health L. & Pol’y 55, 61-62 (2024).
70 Wendy E. Parmet & Faith Khalik, Judicial Review of Public Health Powers Since the Start of the COVID-19 Pandemic: Trends and Implications, 113 Am. J. Pub. Health 280 (2023).
71 The discussion that follows focuses on relatively recent cases that go to the core of public health powers. Other recent doctrinal shifts, including the overturning of Roe v. Wade, Dobbs v. Jackson Women’s Health Ctr., 597 U.S. 215 (2022), and the Court’s embrace of the Second Amendment, N.Y. State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022), also raise significant risks for public health. For a broader discussion of how constitutional law affects health, see Parmet, supra note 7, at 27-49.
72 197 U.S. 11 (1905).
73 Gostin & Wiley, supra note 18, at 121.
74 Wendy E. Parmet, Rediscovering Jacobson in the Era of COVID-19, 100 B.U. L. Rev. Online 117, 119 (2020).
75 Id. at 128. See also S. Bay United Pentecostal Church v. Newsom, 140 S. Ct. 1613, 1613-14 (2020)(Roberts, C.J. concurring); Gostin & Wiley, supra note 18, at 122-26.
76 Wendy E. Parmet, The COVID Cases: A Preliminary Assessment of Judicial Review of Public Health Powers During a Partisan and Polarized Pandemic, 57 S. Diego L. Rev. 999 (2020).
77 Calvary Christian Dayton Valley v. Sisolak, 140 S. Ct. 2603 (Alito, J., dissenting).
78 Wendy E. Parmet, From the Shadows: The Public Health Implications of the Supreme Court’s COVID-Free Exercise Cases, 49 J.L. Med. & Ethics 564, 566 (2021).
79 Roman Cath. Dioc. v. Cuomo, 141 S. Ct. 63 (2020). Concurring, Justice Gorsuch wrote that Jacobson was a “modest” decision that had erroneously been treated as a “towering authority.” Id. at 71 (Gorsuch, J., concurring).
80 Tandon v. Newsom, 593 U.S. 61 (2021) (per curiam); Michelle M. Mello, David H. Jiang & Wendy E. Parmet, Judicial Decisions Constraining Public Health Powers, 43 Health Affs. 759, 765 (2024).
81 Fulton v. Philadelphia, 593 U.S. 522 (2021).
82 Mello, Jiang & Parmet, supra note 80, at 765.
83 Compare We the Patriots v. Conn. Off. Early Childhood Dev., 76 F. 4 th 130 (2nd Cir. 2023) with Bosarge v. Edney, 669 F. Supp. 598 (S.D. Miss. 2023). See also Spivak v. City of Philadelphia, No. 23-1212 (3d Cir. July 29, 2023) (denying summary judgement in constitutional challenge to denial of religious exemption, but also holding that the existence of a medical exemption does not undermine a mandate’s “general applicability”).
84 Groff v. DeJoy, 600 U.S. 447 (2023).
85 E.g., McDonald v. Oregon Health & Sci. Univ., 689 F. Supp. 3d 906 (D. Or. 2023); but see Chavez v. San Francisco Bay Area Rapid Transit Dt., 2024 WL 334741 (N.D. Cal. 2024).
86 E.g., Sorrell v. IMS Health Inc., 564 U.S. 552 (2011); Lorillard Tobacco Co. v. Reilly, 533 U.S. 525 (2001).
87 Cent. Hudson Gas & Elec. Corp. v. Pub. Serv. Comm’n, 447 U.S. 557, 566 (1980).
88 Sorrell, 564 U.S. at 572.
89 Zauderer v. Off. Disciplinary Couns., 471 U.S. 626 (1985). The key case narrowing but not overruling Zauderer is Nat’l. Inst. Fam. & Life Advoc. v. Becerra, 585 U.S. 755 (2018).
90 E.g., Am. Bev. Ass’n v. City & Cty. San Francisco, 916 F.3d 749 (9 th Cir. 2019) (en banc); Cigar Ass’n Am. v. U.S. Food & Drug Admin., 317 F. Supp. 3d 555 (2024). But see R.J. Reynolds Tobacco Co. v. Food & Drug Admin., 96 F.4th 863 (5th Cir. 2024) (applying rational basis review to challenge of FDA regulations requiring warning labels on cigarettes).
91 As James G. Hodge Jr. and colleagues note, state “anti-equity” legislation also poses a threat to public health. See James G. Hodge et al., Assessing Impacts of “Anti-Equity” Legislation on Health Care and Public Health Services, 52 J.L. Med. & Ethics 172 (2024).
93 600 U.S. at 181 (2023).
94 Litigation, Do No Harm, https://donoharmmedicine.org/litigation/?location=all&case_status=all&topic=all (last visited Aug. 13, 2024).
95 For example, the Pacific Legal Foundation sued New York City’s Department of Health & Public Hygiene for instructing health-care providers in a note on how to prioritize the allocation of COVID-19 treatments that being non-White should be considered a risk-factor. Although the case was ultimately dismissed for lack of standing, Justice Alito penned a statement citing Students for Fair Admission, warning “in the event that any government again resorts to racial or ethnic classifications to rational medical treatment, there would be a very strong case for prompt review by this Court.” See Roberts v. McDonald, 143 S. Ct. 2425 (2023) (statement of Alito J.).
96 Louisiana v. EPA, No. 2:23-CV-00692, 2024 WL 3904868 (W.D. La. Aug. 22, 2024); Terry L. Jones, Court Permanently Blocks Environmental Civil Rights Protections for Louisiana’s Black Communities, La. Illuminator (Aug. 24, 2024), https://lailluminator.com/2024/08/24/environment-civil-rights/[ https://perma.cc/4SD7-KQA4].
97 See Nathan Richardson, Antideference: COVID, Climate, and the Rise of the Major Questions Canon, 108 Va. L. Rev. Online 174, 185 (2022).
98 Ala. Assoc. Realtors v. CDC, 141 S. Ct. 2489 (2021) (per curiam) (quoting Util. Air Regul. Grp. v. EPA, 573 U.S. 302, 324 (2014) (quoting FDA v. Brown & Williamson Tobacco Corp., 529 U.S. 120, 160 (2000)).
99 Id.
100 Nat’l Fed’n Indep. Bus. v. Dep’t Lab., Occupational Safety and Health Admin., 595 U.S. 109, 112–13 (2022) (per curiam).
101 Louisiana v. Biden, 55 F.4th 1017, 1029, 1031 (5th Cir. 2022); Georgia v. President of the United States, 46 F.4th 1283, 1294–95 (11th Cir. 2022). See also Kentucky v. Biden, 571 F. Supp. 3d 715, 719 (E.D. Ky. 2021), aff’d sub nom. Commonwealth v. Biden, 57 F.4th 545 (2023); Missouri v. Biden, 576 F. Supp. 3d 622, 632 (E.D. Mo. 2021).
102 Health Freedom Def. Fund, Inc. v. Biden, 599 F. Supp. 3d 1144, 1175–76 (M.D. Fla. 2022), vacated as moot sub nom. Health Freedom Def. Fund v. President of U.S., 71 F.4th 888 (11th Cir. 2023).
103 Loper Bright Enters. v. Raimondo, 144 S. Ct. 2244, 2272 (overruling Chevron U.S.A., Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837 (1984)).
104 See Ohio v. Env’t. Prot. Agency, 144 S. Ct. 2040 (EPA’s regulation requiring states to consider downwind impact of pollution was arbitrary and capricious); Corner Post, Inc. v. Bd. of Govs., 144 S. Ct. 2440 (statute of limitations for facial challenges to regulations does not start to run until a party is initially subject to the regulation).
105 Although the Court has overruled precedent throughout its history, it seems to be doing so more frequently and with more disdain for past rulings. See Austin Sarat, The Supreme Court Has Never in Its History Had This Much Disdain for Precedent, Slate (July 2, 2024), https://slate.com/news-and-politics/2024/07/supreme-court-john-roberts-alito-precedent-disdain-dobbs.html.
106 Loper Bright, 144 S. Ct. at 2298-301 (Kagan, J., dissenting); Parmet, From the Shadows, supra note 78, at 572 (discussing the disregard of scientific evident in the Free Exercise cases).
107 The Supreme Court’s Contempt for Facts Is a Betrayal of Justice, Scientific Amer. (July 10, 2024), https://www.scientificamerican.com/article/the-supreme-courts-contempt-for-facts-is-a-betrayal-of-justice/.
108 Parmet, From Deference to Indifference, supra note 17, at 25-27.
109 Id.
110 Parmet & Khalik, supra note 70, at 280.
111 Id. at 285-86.
112 Erie Railroad Co. v. Tompkins, 304 U.S. 64, 78 (1938).
113 Yong, supra note 13, at 4.
114 Nicholas Freudenberg, From Lifestyle of Social Determinants: New Directions for Community Health Promotion Research and Practice, (2007), https://www.cdc.gov/pcd/issues/2007/jul/06_0194.htm [https://perma.cc/4KET-RLMT].
115 Aziza Ahmed & Jason Jackson, The Public/Private Distinction in Public Health: The Case of COVID-19, 90 Fordham L. Rev. 2541, 2553 (2022).
116 Burris, supra note 22, at 125.
117 Id. at 123-24.
118 Parmet, supra note 7, at 51-55.
119 Burris, supra note 22, at 131-32.
120 Id.
121 For a critique of public health’s ideological conformity, see Sandro Galea, Within Reason: A Liberal Public Health for an Illiberal Time (2023).
122 Burris, supra note 22, at 131-132.
123 Unquestionably, conservative scholars and practitioners write about and practice in areas relating to public health law. Indeed, they have led the assault on public health law in the courts. But although they work in public health law, most are unlikely to consider themselves members of the field, as described above. See supra text accompanying notes 16-26.
124 E.g., Lindsay F. Wiley, Democratizing the Law of Social Distancing, 19 Yale J. Health Pol’y, Law & Ethics 50, 60 (2020)(on the need for guardrails for public health measures); George J. Annas & Wendy K. Mariner, (Public) Health and Human Rights in Practice, 41 Health Affs. 129, 136 (2016) (arguing that public health should “welcome” the human rights framework); Wendy E. Parmet, Quarantining the Law of Quarantine: Why Quarantine Law Does Not Reflect Contemporary Constitutional Law, 9 Wake For. J.L. & Pol’y 1, 28-30 (2019)(respect for public health requires allowing for judicial review of quarantine orders).
125 See Burris, supra note 22, at 126 (noting that “law is hard” and that “a number of strict conditions” must be met if the use of legal powers can achieve their aim).
126 Mello, Jian & Parmet, supra note at 80, at 764-66.
127 Scott Burris and colleagues also emphasize the need for more rigorous scientific study (through legal epidemiology) of the mechanisms and impacts of various policy tools, including law. Burris et al., supra note 26, at 142.
128 Leo Beletsky, Wendy E. Parmet & Scott Burris, Advancing Public Health Through Law: The Role of Legal Academics: Workshop Report, Northeastern Public Law and Theory Faculty Research Papers Series No. 110-2012.
129 Id.
130 Id. at 4.
131 Id.
132 Id.
135 Public Health Law Watch, 2024 Convening (May 22-23, 2024), https://www.publichealthlawwatch.org/2024-convening [https://perma.cc/H8L8-H7KK].
136 Beletsky, Parmet & Burris, supra note 128, at 4.
137 Wiley, Parmet & Jacobson, supra note 65, at 73.
138 Ironically, this may require erosion of the field’s cohesiveness as the boundaries between public health law and allied fields may dissolve.
139 Loper Bright Enters., 144 S. Ct. at 2272.
140 For example, the Supreme Court relied on its decisions blocking CDC’s eviction moratorium in later decisions striking environmental regulations and President Biden’s student loan plans. See Biden v. Nebraska, 143 S. Ct. 2355, 2371 (2023) (citing Ala. Assoc. Realtors v. Dep’t Health & Hum. Servs., 141 S. Ct. 2485 (2021) (per curiam) in blocking loan forgiveness plan); West Virginia v. Env’t. Prot. Agency, 597 U.S. 697, 721 (2022) (citing Ala. Assoc. Realtors in striking EPA’s clean energy rule).
141 Burris, supra note 22, at 125.
142 Parmet & Khalik, supra note 70, at 284.
143 Since 2020, my colleagues and I at Northeastern have run a program, Salus Populi, that seeks to do this. Linda Tvrdy et al., Salus Populi: Educating Judges on the Social Determinants of Health, 108 Judicature 52 (2024). Other such efforts are sorely needed.
145 E.g., Heidi Przybyla, Leonard Leo Used Federalist Society Contract to Obtain $1.6B Donation, Politico, (May 2, 2023, 4:30 AM), https://www.politico.com/news/2023/05/02/leonard-leo-federalist-society-00094761. See also Joanna Wuest & Briana S. Last, Church Against State: How Industry Groups Lead the Religious Liberty Assault on Civil Rights, Healthcare Policy and the Administrative State, 52 J.L. Med. & Ethics 151 (2024).
146 The Network, https://the-network.org/ (last visited Oct. 12, 2024); ChangeLab Solutions, https://www.changelabsolutions.org/ (last visited Oct. 12, 2024).