In 1919, against a backdrop of postwar anti-German sentiment and assimilationist policy, Nebraska enacted the Siman Act. The law forbade any person from teaching any subject in any language other than English to students who had not passed the eighth grade and separately prohibited the teaching of modern foreign languages to such students. Robert T. Meyer, a teacher at a parochial Lutheran school in Nebraska, was charged after he taught a 10-year-old student to read German from a biblical text during a regular school lesson. He was prosecuted, convicted, and fined under the Act. Nebraska courts, including the state supreme court, upheld the law as a valid exercise of the state's police power to promote civic development and the English language. Meyer sought review in the U.S. Supreme Court, arguing that the statute violated the liberty guaranteed by the Due Process Clause of the Fourteenth Amendment, including the rights of parents, teachers, and pupils.
Does a state law that prohibits teaching modern foreign languages to young students and forbids instruction in languages other than English for those students violate the liberty protected by the Due Process Clause of the Fourteenth Amendment?
The Fourteenth Amendment's Due Process Clause protects liberty interests that include, among other things, the rights of parents to direct the upbringing and education of their children, the right of teachers to engage in their common occupation, and the right of students to acquire useful knowledge. While a state may regulate schools and curricula pursuant to its police power, any regulation must bear a reasonable relation to a legitimate state objective and may not arbitrarily or unreasonably interfere with protected liberty interests.
Yes. Nebraska's prohibition on foreign-language instruction for young students unconstitutionally infringes the liberty protected by the Fourteenth Amendment because it is an arbitrary and unreasonable means of pursuing the state's asserted aims.
The Court, speaking through Justice McReynolds, first articulated that the concept of liberty safeguarded by the Fourteenth Amendment encompasses more than freedom from physical restraint; it includes long-recognized interests essential to the orderly pursuit of happiness, such as engaging in common occupations, acquiring useful knowledge, marrying, establishing a home, and bringing up children, and worshiping according to conscience. Within this framework, the Court identified three intertwined liberty interests at stake: the teacher's right to practice his calling, the parents' right to control the education of their children, and the student's right to acquire knowledge. Although the state possesses broad authority to compel school attendance, prescribe reasonable curricula, and promote civic development, those powers are not boundless. The legitimacy of Nebraska's asserted goals was not in doubt; the state may foster the English language and inculcate civic virtues. The constitutional problem lay in the means chosen. The Siman Act categorically barred the teaching of modern foreign languages to students who had not passed the eighth grade and broadly prohibited instruction in languages other than English for younger pupils. The Court concluded that these prohibitions were arbitrary and bore no reasonable relation to the state's interests. The state presented no persuasive basis for believing that acquiring a foreign language at an early age would impair civic development or threaten public safety. To the contrary, the acquisition of language skills is inherently useful and not harmful. A targeted regulation requiring adequate English instruction or ensuring proficiency in English could advance legitimate ends without extinguishing protected liberties, but a blanket criminalization of foreign-language instruction for young students was an unnecessary and unreasonable intrusion. The Court emphasized that due process guards against such arbitrary interferences. The statute did not merely regulate pedagogy; it forbade a harmless and beneficial activity central to both family autonomy and educational freedom. Because the law lacked a real and substantial relation to the state's legitimate objectives and unjustifiably burdened constitutionally protected liberty, the conviction could not stand.
Meyer marks a seminal articulation of substantive due process under the Fourteenth Amendment, placing parental control of education, teachers' occupational liberty, and students' pursuit of knowledge within the ambit of protected liberty. It limited state police power where regulations are arbitrary or unrelated to legitimate ends. Together with Pierce v. Society of Sisters (1925), Meyer anchors the constitutional protection of family autonomy and educational choice, later informing cases involving privacy, family relations, and decisional autonomy. For law students, Meyer is essential for understanding the evolution of substantive due process, the scope of liberty beyond economic rights, and the analytical requirement that state regulations bear a reasonable relation to valid purposes.
Meyer v. Nebraska established that the Fourteenth Amendment's protection of liberty extends to family autonomy in education, the pursuit of common occupations, and the acquisition of knowledge. While permitting states to regulate schools and promote civic values, the decision demands that such regulations be reasonable and nonarbitrary, tethered to legitimate aims without extinguishing protected liberties.