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.
The power of the State to compel attendance at some school and to make reasonable regulations for all schools, including a requirement that they shall give instructions in English, is not questioned.View Full Point of Law
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.