From the earliest weeks of the pandemic, courts and commentators turned to Jacobson v. Massachusetts for guidance. The 1905 Supreme Court case upheld a statute authorizing local boards of health to make smallpox vaccination compulsory if, in the board’s opinion, it was necessary for the public health. Led by the Fifth Circuit, many courts interpreted Jacobson as dictating a highly deferential “suspension” standard for judicial review of public health emergency orders – a throwback to the standard commonly applied to any constitutional violation in 1905. Judges relied on Jacobson to uphold infringements upon abortion rights, voting rights, and freedoms of worship, assembly, association, and movement. In a November 2020 decision, the Supreme Court majority apparently rejected the Jacobson suspension standard, at least for Fourteenth Amendment claims. This chapter parses the fractured opinions in Roman Catholic Diocese of Brooklyn v. Cuomo and subsequent lower court opinions for indications of Jacobson’s continued vitality as a lodestar for public health powers. The chapter rejects the Jacobson suspension doctrine in favor of a broader reading that provides guidance for judicial review on separation of powers and federalism questions as well as individual rights. Jacobson offers enduring and flexible guidance on the two tensions at the heart of public health law and policy, which have been brought into stark relief by the pandemic but will continue to be litigated long after the COVID-19 threat has subsided: first, the tension between individual rights and the common good; and second, the tension between bureaucratic expertise and democratic accountability.