Two distinct points of view have developed with regard to judicial review of public health actions. One view is derived from a careful reading of past public health decisions related to communicable disease control. Courts require health actions to have reasonable medical support and a public health value that outweighs their cost to individuals. A second view begins in general constitutional law and applies the rational basis test and principles of deference to State political decisions regarding the exercise of police power. Following this view, courts reviewing constitutional challenges to health actions use the same test in health cases as they do in any other challenge under equal protection or substantive due process clauses. There has been a tendency to think of public health cases as striking a balance between individual rights and public welfare. The prime issue is delineating the public's freedom to identify what is good public health policy and to select the means by which to achieve it. The practice of traditional health decisions requires that any health action have a rational medical relationship to the goal of protecting public health. The degree to which courts will overturn "quietly hysterical" health decisions will depend on their willingness to engage in sophisticated cultural and medical analysis. 167 footnotes