In THE INTEREST OF C.C., Children

John and Brittani Chandler's three children were removed from their home and placed in the custody of the Division of Family and Children Services (DFCS) after a Lumpkin County court found the children dependent. When the case moved to the Forsyth County Juvenile Court, the Chandlers objected on religious grounds to DFCS vaccinating their children. The juvenile court denied their objection, finding that the Chandlers did not sincerely hold a religious belief against vaccination, and also ruled against them on the constitutional and statutory merits. The Supreme Court of Georgia reviewed that decision and first refused to dismiss the case as moot even though DFCS adopted a new policy respecting religious objections and said it no longer sought to vaccinate the children, partly because one child was vaccinated days after the policy was announced. On the merits, the court held that whether the Chandlers sincerely hold their religious belief is a threshold question that must be answered correctly before any of the harder constitutional or statutory issues can be decided. Because the juvenile court wrongly assumed a belief must be tied to organized religious practice to count as sincere, the Supreme Court sent the case back for the juvenile court to apply the correct sincerity standard.

A parent's religious objection to a child's vaccination must be evaluated for sincerity using a proper legal standard that does not require regular church attendance or affiliation with an organized religion, because a belief can be both secular and religious and still be sincerely held.

The ruling gives Georgia juvenile courts clearer guidance for evaluating parents' claimed religious objections to medical care for children in foster custody, affecting how DFCS handles vaccinations statewide and how seriously courts must probe sincerity before ruling on constitutional claims.

Judgment vacated and case remanded with direction

1. The court explained that sincerity, meaning whether a religious belief is genuinely and truly held rather than feigned, is a required first step before any of the Chandlers' claims can be considered, because both their First Amendment free exercise argument and their vagueness claim under Georgia's dependency statute (O.C.G.A. § 15-11-30) depend on their beliefs being sincere and actually held.
2. Because deciding the underlying constitutional and statutory questions would require resolving important, novel, and difficult issues about parental religious rights versus the state's custodial authority, the court applied the principle of constitutional avoidance, meaning courts should not decide hard constitutional questions unless truly necessary, and found that the sincerity issue offered a way to avoid those questions for now.
3. The court found that the juvenile court's insincerity finding was legally flawed because it appeared to rest on the idea that the Chandlers could not have a sincere religious belief unless they consistently attended church or belonged to an organized religion, when in fact a belief can be both secular and religious at the same time and still qualify for protection.
4. Because an appellate court generally defers to a trial court's factual findings on credibility but cannot do so when the trial court used the wrong legal framework, the Supreme Court of Georgia could not simply affirm or independently decide the sincerity question itself and instead had to send the case back.
5. The court laid out factors the juvenile court should weigh on remand, such as how long the belief has been held, the family's knowledge of religious teachings supporting it, consistency and transparency in raising the objection, and cautioned against giving too much weight to inconsistent religious practice, such as spotty church attendance.

• religious objection to vaccination
• foster care custody
• free exercise clause
• dependency proceedings
• DFCS