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Meyer v. Nebraska

    Citation. 262 U.S. 390, 43 S. Ct. 625, 67 L. Ed. 1042, 1923 U.S.

    Brief Fact Summary. The Petitioner, Meyer (Petitioner), was tried and convicted of teaching reading in German to a 10-year-old student in violation of state laws regulating the teaching of foreign languages.

    Synopsis of Rule of Law. The right of parental control also extends to the type of education children receive.

    Facts. The Respondent, the state of Nebraska (Respondent), made it illegal to teach any class in a non-English language, to teach any non-English language to a pupil prior to the ninth grade and set fines and jail time for any individual violating the statute.

    Issue. May the State of Nebraska outlaw foreign-language instruction?

    Held. No. Justice James McReynolds (J. McReynolds) notes that “mere knowledge of the German language cannot be reasonably regarded as harmful.” As such, it is difficult to ascertain why the Respondent should so influence the educational opportunities of the children of the State and interfere with parental choice of educational experiences.

    Discussion. J. McReynolds notes that the justification for the statute was most likely anti-German sentiment following the First World War. He also suggests that the statute may not be unconstitutional in wartime, when the State’s interest in fostering a homogeneous population with “American ideals,” is far greater than during peacetime. Meyer is clearly indicative of jurisprudence prior to the development of the fundamental right/compelling state interest/substantial relation analysis of the current Supreme Court of the United States (Supreme Court).


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