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Law School Case Brief

Meyer v. Nebraska - 262 U.S. 390, 43 S. Ct. 625 (1923)

Rule:

The liberty guaranteed under U.S. Const. amend. XIV denotes not merely freedom from bodily restraint but also the right of the individual to contract, to engage in any of the common occupations of life, to acquire useful knowledge, to marry, establish a home and bring up children, to worship God according to the dictates of his own conscience, and generally to enjoy those privileges long recognized at common law as essential to the orderly pursuit of happiness by free men.

Facts:

On May 15, 1920, Meyer, an instructor in Zion Parochial School, taught the subject of reading in the German language to Raymond Parpart, a child of ten years, who had not attained and successfully passed the eighth grade. Meyer was consequently charged of violating a Nebraska statute which forbade the teaching of a foreign language to a student who had not passed the eighth grade. He was convicted of the same. On review, the Nebraska Supreme Court affirmed the conviction and held that the statute was a valid exercise of the state's police power. Thereafter, Meyer sought a review of the state supreme court’s judgment.

Issue:

Was the Nebraska statute, which forbade the teaching of a foreign language to a student who has not passed the eighth grade, a valid exercise of the state's police power?

Answer:

No.

Conclusion:

The United States Supreme Court held that the statute was arbitrary and without reasonable relation to any legitimate state goal. The Court further held that the liberty guaranteed by U.S. Const. amend. XIV protected the teacher's right to teach and the right of parents to engage the teacher in educating their children. The Court stated that education and acquisition of knowledge were matters of supreme importance that should be diligently promoted. According to the Court, the state could not, under the guise of exercising its police power, interfere with such guaranteed liberty interests. The Court found that, by the statute, the legislature was attempting to materially interfere with the calling of modern language teachers, with the opportunities of students to acquire knowledge, and with the power of parents to control the education of their own children. Thus, the teacher's conviction was based on an unconstitutional statute and was consequently reversed.

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