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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:

Plaintiff Meyer, a teacher, while working in a parochial school, was convicted for teaching the German language to a 10-year old child who had not successfully passed the eighth grade, in violation of 1919 Neb. Laws ch. 249—a statute that prohibited teaching of languages other than English to children who had not passed the eighth grade. The state supreme court had held that the statute was a valid exercise of the State's police power. Thereafter, Meyer appealed.

Issue:

Was the statute a valid exercise of the State's police power?

Answer:

No.

Conclusion:

The 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. According to the Court, education and acquisition of knowledge were matters of supreme importance that should be diligently promoted. As such, 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 in question, 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 Court ruled that Meyer’s conviction was based on an unconstitutional statute.

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