Facts
- Nebraska enacted a 1919 law requiring instruction in English and prohibiting teaching any subject in a language other than English; it also barred teaching modern foreign languages to students who had not completed eighth grade.
- Robert T. Meyer, a teacher at a parochial school in Hamilton County, Nebraska, taught reading in German to a 10-year-old student who had not passed eighth grade.
- Meyer was charged, tried, and convicted in Nebraska district court for violating the statute and was fined.
- The Nebraska Supreme Court affirmed, treating the law as a valid exercise of police power aimed at civic development and unity by limiting foreign-language education for young children.
- Meyer sought review in the U.S. Supreme Court, challenging the statute under the Fourteenth Amendment.
Issues
- Whether the Fourteenth Amendment’s Due Process Clause “liberty” protects a teacher’s right to teach and a parent’s right to direct a child’s education in a modern foreign language.
- Whether Nebraska’s prohibition on teaching modern foreign languages to children below eighth grade, as applied to German instruction in a parochial school, is a reasonable exercise of the state’s police power.
- Whether the statute is arbitrary or lacks a reasonable relation to a legitimate state end.
Decision
- The U.S. Supreme Court reversed the Nebraska Supreme Court and vacated Meyer’s conviction.
- The Court held that the statute, as applied, invaded the liberty protected by the Fourteenth Amendment and exceeded the state’s power.
- The Court accepted that a state may regulate schooling and require attendance, but concluded this restriction on language instruction was not reasonably related to a permissible state objective.
- Justices Holmes and Sutherland dissented without written opinions.
Legal Principles
- “Liberty” under the Fourteenth Amendment includes more than freedom from physical restraint and protects certain personal choices, including acquiring knowledge and bringing up children.
- Protected liberty interests include: a teacher’s right to pursue a lawful calling, parents’ right to control their children’s education, and a child’s interest in receiving instruction.
- A state’s police power to regulate education is broad but not unlimited; regulations must not be arbitrary and must bear a reasonable relation to an end within the state’s authority.
- The state may not justify restrictions on constitutionally protected liberty by invoking general civic goals when the means chosen are unreasonable in relation to those goals.
Conclusion
The Court invalidated Nebraska’s restriction on teaching modern foreign languages to students below eighth grade as applied to parochial-school German instruction, recognizing substantive due process protection for educational and parental choices within the Fourteenth Amendment’s guarantee of liberty.