Prince v. Massachusetts
| Prince v. Massachusetts | |
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| Argued December 14, 1943 Decided January 31, 1944 |
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| Full case name | Prince v. Commonwealth of Massachusetts |
| Citations | 321 U.S. 158 (more) |
| Court membership | |
| Case opinions | |
| Majority | Rutledge |
| Dissent | Murphy |
| Dissent | Jackson, joined by Roberts and Frankfurter |
Prince v. Massachusetts, 321 U.S. 158 (1944), was a case in which the Supreme Court of the United States held that the government has broad authority to regulate the actions and treatment of children. Parental authority is not absolute and can be permissibly restricted if doing so is in the interests of a child's welfare. While children share many of the rights of adults, they face different potential harms from similar activities.
A Jehovah's Witness woman named Sarah Prince was convicted for violating child labor laws. She was the guardian of a nine-year-old girl, Betty M. Simmons, whom she had brought into a downtown area to preach on the streets. This preaching involved distributing literature in exchange for voluntary contributions. The child labor laws that she was charged with violating stipulated that no boys under 12 and no girls under 18 were permitted to sell literature or other goods on public thoroughfares.
There were three complaints filed against Prince:
Both Prince and her husband were ordained ministers and commonly took their children out to distribute religious literature. Prince argued that the state's child labor laws violated her Fourteenth Amendment rights to exercise her religion and her equal protection rights, in particular because the children themselves were ministers of their religion as well.
In a 5–4 decision, with Justice Rutledge writing the majority opinion, the Supreme Court upheld Massachusetts' laws restricting the abilities of children to sell religious literature. The decision asserted that the government has broad authority to regulate the actions and treatment of children. Parental authority is not absolute and can be permissibly restricted if doing so is in the interests of a child's welfare. While children share many of the rights of adults, they face different potential harms from similar activities.
One issue that the Court considered was whether a parent's presence makes it permissible for the child to engage in actions that would otherwise be prohibited. Noting that the dangers would still exist, the Court decided that the state was free to legislate against this activity, even if adults were allowed to engage in them. The opinion included these assertions:
The family itself is not beyond regulation in the public interest, as against a claim of religious liberty. And neither the rights of religion nor the rights of parenthood are beyond limitation…The right to practice religion freely does not include the right to expose the community or the child to communicable disease or the latter to ill-health or death...
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