In the 1906 case of Appleyard v. Massachusetts, the U.S. Supreme Court upheld a state law that required vaccination during an outbreak of smallpox. The plaintiff, Mr. Appleyard, was convicted for refusing to be vaccinated and appealed his conviction on constitutional grounds claiming it violated his Fourteenth Amendment rights to liberty and property without due process of law. However, the court ruled against him stating that individual liberties could be curtailed in order to protect public health and safety under police power doctrine - a principle allowing states to regulate behavior and enforce order within their territory for betterment of health, safety, morals or general welfare of their inhabitants.

The dissenting opinion in the Appleyard v. Massachusetts case argued that the state law requiring vaccination was an infringement on personal liberty and a violation of the Fourteenth Amendment, which guarantees due process rights. The justice contended that while states have broad powers to enact laws for public health and safety, these powers are not absolute and must be balanced against individual liberties. He asserted that compulsory vaccination could lead to potential abuses by authorities under the guise of protecting public health. Furthermore, he questioned whether mandatory vaccinations were truly necessary or effective in preventing disease spread, suggesting alternative measures might achieve similar results without infringing on personal freedoms. Thus, he disagreed with majority's upholding of such mandates as constitutional.