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The Supreme Court case of Jacobson v. Massachusetts will be used by governors throughout America as legal authority for the state-of-emergency orders they’ve issued. In 1905, Jacobson challenged a Massachusetts law making smallpox vaccination compulsory. He argued that the law violated the 14th Amendment which prohibits states from enacting legislation that conflicts with the U.S. Constitution or deprives a citizen of life, liberty, or property without due process of law. The Court rejected Jacobson’s argument ruling that “the state may be justified in restricting individual liberty…under the pressure of great dangers.” In such cases, the Court will invalidate state laws only if they have no reasonable relation to protecting the public welfare or if they “palpably conflict with the Constitution” .