Facts
- Wisconsin law required parents to ensure school attendance until age 16.
- Jonas Yoder and Wallace Miller (Old Order Amish) and Adin Yutzy (Conservative Amish Mennonite) refused, on religious grounds, to send their children (ages 14–15) to high school after completion of eighth grade.
- The State stipulated the parents’ religious beliefs were sincere.
- The parents presented uncontradicted evidence that compulsory high school attendance conflicted with central religious duties and threatened the continued existence of their religious communities.
- The Amish families showed that after eighth grade they provided informal vocational training and community-based instruction designed to prepare children for productive, law-abiding lives within their communities.
Issues
- Whether applying Wisconsin’s compulsory school-attendance law to require Amish children to attend high school violates the Free Exercise Clause of the First Amendment (as applied to the States).
- Whether the State’s interest in compulsory education until age 16 justifies the burden imposed on the parents’ religious exercise.
Decision
- The Court affirmed the judgment setting aside the convictions (6–1).
- The Court held that compelling Amish parents to send their children to high school imposed a severe burden on religious exercise through threat of criminal sanction.
- The Court concluded Wisconsin’s asserted interests in compulsory education to age 16, though substantial, were insufficient on this record to override the parents’ Free Exercise rights.
- The Court relied on evidence that the Amish alternative education and vocational training adequately served the State’s basic interests in preparing children for adult life and civic responsibility.
- The Court limited the holding to the specific facts showing a longstanding religious community, a central religious objection to high school attendance, and a demonstrated educational alternative.
Legal Principles
- A state’s interest in universal education is subject to constitutional limits when enforcement substantially burdens Free Exercise and parental authority over religious upbringing.
- When a law affirmatively compels conduct contrary to sincere, central religious beliefs under threat of criminal penalty, the State must show a sufficiently weighty justification.
- Religious exemptions from generally applicable education requirements may be warranted where the record shows (1) a grave conflict with religious practice and (2) an alternative mode of education that addresses the State’s basic educational objectives.
- The Court’s analysis is fact-specific and does not create a general right for parents to avoid compulsory schooling based on any religious or philosophical objection.
Conclusion
The Court held that Wisconsin could not constitutionally require Amish parents, consistent with their established religious practices and proven alternative education, to send their children to high school, because the law’s severe burden on Free Exercise was not justified by the State’s interest in compulsory attendance to age 16 on the record presented.