Meyer v.

Nebraska
Citation. 262 U.S. 390,43 S. Ct. 625,67 L. Ed. 1042,1923 U.S.
Brief Fact Summary. Plaintiff was convicted for teaching a child German under a Nebraska statute
that outlawed the teaching of foreign languages to students that had not yet completed the eighth
grade.
Synopsis of Rule of Law. The Fourteenth Amendment prohibits states from creating legislation that
restricts liberty interests when the legislation is not reasonably related to an acceptable state
objective.
Facts. Plaintiff was convicted for teaching a child German under a Nebraska statute that outlawed
the teaching of foreign languages to students that had not yet completed the eighth grade. The
Supreme Court of Nebraska upheld the conviction.
Issue. Does the statute as construed and applied unreasonably infringe on the liberty guaranteed by
the Fourteenth Amendment?
Held. The statute as applied is unconstitutional because it infringes on the liberty interests of the
plaintiff and fails to reasonably relate to any end within the competency of the state.
The Fourteenth Amendment encompasses more than merely the freedom from bodily restraint. The
state argues that the purpose of the statute is to encourage the English language to be the native
tongue of all children raised in the state. Nonetheless, the protection of the Constitution extends to
those who speak other languages. Education is a fundamental liberty interest that must be
protected, and mere knowledge of the German language cannot be reasonably regarded as harmful.
Discussion. Liberty interests may not be interfered with by the states when the interference is
arbitrary and not reasonably related to a purpose which the state may permissively regulate.

Pierce v. Society of Sisters

Citation. 268 U.S. 510,45 S. Ct. 571,69 L. Ed. 1070,1925 U.S.
Brief Fact Summary. Appellees, two non-public schools, were protected by a preliminary restraining
order prohibiting appellants from enforcing an Oregon Act that required parents and guardians to
send their children to public school. Appellants appealed the order.
Synopsis of Rule of Law. The 14th Amendment provides a liberty interest in a parents or guardians
right to decide the mode in which their children are educated. States may not usurp this right when
the questioned legislation does not reasonably relate to a viable state interest.
Facts. Appellee the Society of Sisters, a corporation with the power to establish and maintain
academies or schools and Appellee Hill Military Academy, a private organization conducting an
elementary, college preparatory, and military training school, obtained preliminary restraining
orders prohibiting appellants from enforcing Oregons Compulsory Education Act. The Act required

all parents and guardians to send children between 8 and 16 years to a public school. The appellants
appealed the granting of the preliminary restraining orders.
Issue. Does the Act unreasonably interfere with the liberty of parents and guardians to direct the
upbringing and education of children under their control?
Held. The Act violates the 14th Amendment because it interferes with protected liberty interests and
has no reasonable relationship to any purpose within the competency of the state.
The Appellees have standing because the result of enforcing the Act would be destruction of the
appellees schools. The state has the power to regulate all schools, but parents and guardians have
the right and duty to choose the appropriate preparation for their children.
Discussion. While the state has the right to insure that children receive a proper education, the 14th
Amendment provides parents and guardians with a liberty interest in their choice in the mode in
which their children are educated.

Wisconsin v. Yoder
Citation. 22 Ill.406 U.S. 205, 92 S. Ct. 1526, 32 L. Ed. 2d 15 (1972)
Brief Fact Summary. The Respondents, Yoder and other members of a Wisconsin Amish community
(Respondents) took issue with the States compulsory education law, maintaining that keeping
children in school until the age of sixteen was against their religious principals, in violation of the
Free Exercise Clause.
Synopsis of Rule of Law. When a true religious interest exists, a state cannot enforce a law, which
abrogates that interest, provided the public interest in enforcing the law is not otherwise burdened.
Facts. The Respondents refused to send their children to school after they completed the eighth
grade, in conformance with their religious practices. The Petitioner, the State of Wisconsin
(Petitioner), brought an action seeking to enforce its compulsory education law. The Respondents
were convicted in violation of the law. The Supreme Court of Wisconsin reversed, sustaining the
Respondents argument that their actions fell under the Free Exercise Clause of the First
Amendment of the United States Constitution (Constitution). Wisconsin appealed, and the Supreme
Court of the United States (Supreme Court) granted certiorari.
Issue. This case considers whether members of a religious community can be compelled to follow a
compulsory education scheme, which could be detrimental to their own religious teachings.
Held. Affirmed.
After applying a balancing test and determining that the interests of the state in compelling
attendance were secondary to the Amish community in preserving its traditions of informal
vocational education, the Supreme Court upheld the ruling of the Wisconsin Supreme Court.

Dissent. Justice William Douglas (J. Douglas) dissented, noting that the claims brought herein were
by parents and may not have necessarily been the viewpoints of their high-school-age children.
Concurrence. Justice Potter Stewart (J. Stewart) and Justice Byron White (J. White) concurred in the
judgment of the Supreme Court.
Discussion. While there are valid governmental interests to be upheld by compulsory education
schemes, these interests do not necessarily outweigh the Free Exercise of religion as mandated by
the First Amendment of the Constitution.