Court: Supreme Court of the United States; June 4, 1923; Federal Supreme Court; Federal Appellate Court
In Meyer v. State of Nebraska, the plaintiff was convicted for unlawfully teaching reading in German to a ten-year-old student at Zion Parochial School, violating Nebraska's 1919 statute that prohibited teaching any subject in languages other than English before a student passed the eighth grade. The law was enacted to prevent the potential negative effects of foreign language instruction on children of immigrants, aiming to ensure that all children in Nebraska would have English as their primary language and mother tongue. The Nebraska Supreme Court upheld the conviction, affirming that the statute was a valid exercise of the state's police power and did not conflict with the Fourteenth Amendment. The court noted that the law served a clear purpose by promoting the English language as essential for the integration of children into American society, despite arguments that it unfairly restricted the rights of citizens not of foreign ancestry.
The argument presented is flawed as it incorrectly assumes that all citizens are equally impacted by the statute in question. The time a child can devote to studying in school is limited, necessitating a careful selection of subjects due to their capacity for learning. The law predominantly affects citizens of foreign lineage, as most citizens typically do not prioritize foreign language education for their children before the eighth grade. The legislature likely considered the practical implications of the law and deemed its benefits to outweigh any minor restrictions imposed.
The critical issue is whether the statute, as interpreted and enforced, unreasonably infringes on the plaintiff's rights under the Fourteenth Amendment, which protects individuals from being deprived of life, liberty, or property without due process. While the court has not precisely defined "liberty," it encompasses more than just freedom from physical restraint; it includes rights related to employment, education, marriage, family, worship, and the pursuit of happiness.
The established principle is that legislative interference with individual liberty must not be arbitrary or lack a reasonable relationship to a legitimate state interest. Legislative determinations regarding police power are not absolute and can be reviewed by the courts. Education and knowledge acquisition are historically valued by Americans, as highlighted by the Ordinance of 1787, which emphasizes the importance of education for good governance and public welfare.
Parents have a natural duty to provide their children with an education appropriate to their social status, a responsibility enforced by compulsory education laws in many states, including Nebraska. Effective education typically occurs in schools led by qualified educators. Teaching foreign languages, such as German, has historically been viewed as beneficial, and the right to teach these languages falls within the liberties protected by the Constitution. However, the statute in question prohibits teaching subjects in any language other than English before students reach the eighth grade, which usually occurs around age twelve. While dead languages like Latin, Greek, and Hebrew are exempt from this law, other languages, including German, French, and Spanish, are banned, thereby infringing on the rights of modern language teachers and parents to direct their children's education.
The legislation aims to promote civic development by limiting exposure to foreign languages and ideals, asserting that children should learn English first to foster American ideals. Concerns are expressed about the large foreign-born population and the influence of foreign customs on citizenship. Although the state has broad authority to improve its citizenry, it must respect individual constitutional rights, including those of non-English speakers. Education cannot be mandated in a way that contradicts constitutional protections. Historical references to Plato and Sparta illustrate that while some philosophical ideas supported collectivism over individuality, such approaches are incompatible with the foundational principles of American governance. Therefore, the imposition of such educational restrictions would violate both the letter and spirit of the Constitution.
The Legislature's intention to promote a unified populace aligned with American ideals, particularly in light of past conflicts, is acknowledged. However, the methods implemented exceed state power and infringe on the rights of the plaintiff. While the state's authority to mandate school attendance and establish reasonable regulations, including English instruction, is recognized, the specific prohibition upheld by the Supreme Court is contested. Citing *Adams v. Tanner*, the document emphasizes that the mere presence of abuse in a generally beneficial occupation does not warrant its abolition, although regulation is permissible. There is no current emergency justifying the ban on teaching a language other than English, which infringes upon previously upheld rights. The statute is deemed arbitrary, lacking a reasonable connection to a legitimate state interest, especially since it only targets modern language instruction while allowing freedom in other educational areas. Proficiency in a foreign language is not harmful to a child's health or development, and thus the lower court's judgment is reversed, with the case remanded for further proceedings. Justices Holmes and Sutherland dissent.
