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Lau v. Nichols

Lau v. Nichols
Seal of the United States Supreme Court.svg
Argued December 10, 1973
Decided January 21, 1974
Full case name Lau, et al. v. Nichols, et al. ( Alan Nichols- President of the school board)
Citations 414 U.S. 563 (more)
94 S. Ct. 786; 39 L. Ed. 2d 1; 1974 U.S. LEXIS 151
Prior history Certiorari to the United States Court of Appeals for the Ninth Circuit
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William O. Douglas · William J. Brennan, Jr.
Potter Stewart · Byron White
Thurgood Marshall · Harry Blackmun
Lewis F. Powell, Jr. · William Rehnquist
Case opinions
Majority Douglas, joined by Brennan, Marshall, Powell, Rehnquist
Concurrence Stewart, joined by Burger, Blackmun
Concurrence White
Concurrence Blackmun, joined by Burger
Laws applied
Civil Rights Act of 1964

Lau v. Nichols, 414 U.S. 563 (1974), was a United States Supreme Court case in which the Court unanimously decided that the lack of supplemental language instruction in public school for students with limited English proficiency violated the Civil Rights Act of 1964. The court held that since non-English speakers were denied a meaningful education, the disparate impact caused by the school policy violated the Civil Rights Act of 1964 and the school district was demanded to provide students with "appropriate relief".

In 1971, the San Francisco school system desegregated based on the result of Supreme Court case Lee v. Johnson. 2856 Chinese students, who were not fluent in English, were integrated back into the San Francisco Unified School District (SFUSD). Only about 1000 of those students were provided supplemental English instruction. Of the other 1800-plus Chinese students who weren't fluent in English, many were placed in special education classes while some were forced to be in the same grade for years.

Even though the Bilingual Education Act was passed by Congress in 1968 to address the needs of Limited English Speaking Abilities students, the funding was limited since it only supported programs for children between the ages between 3 and 8. School participation in those programs was also voluntary, and by 1972, "only 100,391 students nationally, out of approximately 5,000,000 in need were enrolled in a Title VII-funded program."

Edward H. Steinman, a public-interest lawyer, reached out to the parents of Kinney Kinmon Lau and other Chinese students with limited English proficiency. He encouraged them to challenge the school district, and they filed a class action suit against Alan H. Nichols, the president of the SFUSD at the time, and other officials in the school district. The students claimed that they were not receiving special help in school due to their inability to speak English, and they argued they were entitled to special help under the Fourteenth Amendment and the Civil Rights Act of 1964 because of equal protection and the ban on educational discrimination.


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