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Meyer v. Nebraska

Meyer v. Nebraska
Seal of the United States Supreme Court.svg
Argued February 23, 1923
Decided June 4, 1923
Full case name Meyer v. State of Nebraska
Citations 262 U.S. 390 (more)
43 S. Ct. 625; 67 L. Ed. 1042; 1923 U.S. LEXIS 2655; 29 A.L.R. 1446
Prior history Error to the Supreme Court of the State of Nebraska
Holding
A 1919 Nebraska law prohibiting the teaching of modern foreign languages to grade-school children violated the Due Process clause of the 14th Amendment.
Court membership
Case opinions
Majority McReynolds, joined by Taft, McKenna, Van Devanter, Brandeis, Butler, Sanford
Dissent Holmes, joined by Sutherland
Laws applied
U.S. Const. amend. XIV

Meyer v. Nebraska, 262 U.S. 390 (1923), was a U.S. Supreme Court case that held that a 1919 Nebraska law restricting foreign-language education violated the Due Process clause of the Fourteenth Amendment.

World War I witnessed an extensive campaign against all things German, such as the performance of German music at symphony concerts and the meetings of German-American civic associations. Language was a principal focus of legislation at the state and local level. It took many forms, from requiring associations to have charters written in English to a ban on the use of German within the town limits. Some states banned foreign language instruction, while a few banned only German. Some extended their bans into private instruction and even to religious education. A bill to create a Department of Education at the federal level was introduced in October 1918, designed to restrict federal funds to states that enforced English-only education. An internal battle over conducting services and religious instruction in German divided the Lutheran churches.

On April 9, 1919, Nebraska enacted a statute called "An act relating to the teaching of foreign languages in the state of Nebraska," commonly known as the Siman Act. It imposed restrictions on both the use of a foreign language as a medium of instruction and on foreign languages as a subject of study. With respect to the use of a foreign language while teaching, it provided that "No person, individually or as a teacher, shall, in any private, denominational, parochial or public school, teach any subject to any person in any language other than the English language." With respect to foreign-language education, it prohibited instruction of children who had yet to successfully complete the eighth grade.

On May 25, 1920, Robert T. Meyer, while an instructor in Zion Parochial School, a one-room schoolhouse in Hampton, Nebraska, taught the subject of reading in the German language to 10-year-old Raymond Parpart, a fourth-grader, the Hamilton County Attorney entered the classroom and discovered Parpart reading from the Bible in German. He charged Meyer with violating the Siman Act.

Meyer was tried and convicted in the district court for Hamilton county, Nebraska, and fined $25 ($299 in today's dollars). The Nebraska Supreme Court affirmed his conviction by a vote of 4 to 2. The majority thought the law a proper response to "the baneful effects" of allowing immigrants to educate their children in their mother tongue, with results "inimical to our own safety." The dissent called the Siman Act the work of "crowd psychology."


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