Landmark Supreme Court Case: Meyer v. Nebraska (1923)
Meyer v. Nebraska (1923) is the 48th landmark Supreme Court case, the second in the Education module, featured in the KTB Prep American Government and Civics Series designed to acquaint users with the origins, concepts, organizations, and policies of the United States government and political system. The goal is greater familiarization with the rights and obligations of citizenship at the local, state, national, and global levels and the history of our nation as a democracy. While there is overlap, these landmark cases are separated into cases addressing:
- Foreign Policy
- Science & Technology
- Public Safety
- Death Penalty
- Speech, Press, and Protest
- Criminal Justice
- Politics, Society, Freedom, and Equality
The Supreme Court
The Supreme Court is the highest court in the United States. Article III of the U.S. Constitution created the Supreme Court and authorized Congress to pass laws establishing a system of lower courts. The Constitution elaborated neither the exact powers and prerogatives of the Supreme Court nor the organization of the Judicial Branch as a whole. Thus, it has been left to Congress and to the Justices of the Court through their decisions to develop the Federal Judiciary and a body of Federal law.
The number of Justices on the Supreme Court changed six times before settling at the present total of nine in 1869. Since the formation of the Court in 1790, there have been only 17 Chief Justices* and 102 Associate Justices, with Justices serving for an average of 16 years. On average a new Justice joins the Court almost every two years.
The Supreme Court of the United States hears about 100 to 150 appeals of the more than 7,000 cases it is asked to review every year. That means the decisions made by the 12 Circuit Courts of Appeals across the country and the Federal Circuit Court are the last word in thousands of cases.
Court of Appeals
In the federal court system’s present form, 94 district level trial courts and 13 courts of appeals sit below the Supreme Court. The 94 federal judicial districts are organized into 12 regional circuits, each of which has a court of appeals. The appellate court’s task is to determine whether or not the law was applied correctly in the trial court. Appeals courts consist of three judges and do not use a jury.
The appellate courts do not retry cases or hear new evidence. They do not hear witnesses testify. There is no jury. Appellate courts review the procedures and the decisions in the trial court to make sure that the proceedings were fair and that the proper law was applied correctly.
A court of appeals hears challenges to district court decisions from courts located within its circuit, as well as appeals from decisions of federal administrative agencies. In addition, the Court of Appeals for the Federal Circuit has nationwide jurisdiction to hear appeals in specialized cases, such as those involving patent laws, and cases decided by the U.S. Court of International Trade and the U.S. Court of Federal Claims.
The nation’s 94 trial courts are called U.S. District Courts. At a trial in a U.S. District Court, witnesses give testimony and a judge or jury decides who is guilty or not guilty — or who is liable or not liable. District courts resolve disputes by determining the facts and applying legal principles to decide who is right.
Trial courts include the district judge who tries the case and a jury that decides the case. Magistrate judges assist district judges in preparing cases for trial. They may also conduct trials in misdemeanor cases.
There is at least one district court in each state, and the District of Columbia. Each district includes a U.S. bankruptcy court as a unit of the district court.
Federal courts have exclusive jurisdiction over bankruptcy cases involving personal, business, or farm bankruptcy. This means a bankruptcy case cannot be filed in state court. Bankruptcy Appellate Panels (BAPs) are 3-judge panels authorized to hear appeals of bankruptcy court decisions. These panels are a unit of the federal courts of appeals, and must be established by that circuit. Five circuits have established panels: First Circuit, Sixth Circuit, Eighth Circuit, Ninth Circuit, and Tenth Circuit.
Meyer v. Nebraska (1923)
On April 9, 1919, Nebraska enacted a statute called “An act relating to the teaching of foreign languages in the state of Nebraska”, commonly known as the Siman Act. It imposed restrictions on both the use of a foreign language as a medium of instruction and on foreign languages as a subject of study.
With respect to the use of a foreign language while teaching, it provided that:
No person, individually or as a teacher, shall, in any private, denominational, parochial or public school, teach any subject to any person in any language other than the English language
With respect to foreign-language education, it prohibited instruction of children who had yet to successfully complete the eighth grade.
On May 25, 1920, Robert T. Meyer, while an instructor in Zion Lutheran School, a one-room schoolhouse in Hampton, Nebraska, taught the subject of reading in the German language to 10-year-old Raymond Parpart, a fourth-grader. The Hamilton County Attorney entered the classroom and discovered Parpart reading from the Bible in German. He charged Meyer with violating the Siman Act.
Meyer was tried and convicted in the district court for Hamilton County, and was fined $25 (about $320 in 2019 dollars). The Nebraska Supreme Court affirmed his conviction by a vote of 4 to 2 ruling the law a proper response to “the baneful effects” of allowing immigrants to educate their children in their mother tongue, with results “inimical to our own safety”. Meyer appealed to the Supreme Court of the United States.
Q: Did the Nebraska statute violate the Fourteenth Amendment’s Due Process Clause?
A: Yes. The Court declared the Nebraska law unconstitutional, reasoning it violated the liberty protected by Due Process Clause of the Fourteenth Amendment.
7-2 decision ruling a 1919 Nebraska law prohibiting the teaching of modern foreign languages to grade-school children violated the Due Process clause of the 14th Amendment. Liberty includes more than just freedom from bodily restraint. Here, it includes:
- The right of a teacher to teach German to a student
- The right of parents to control the upbringing of their child as they see fit.
Meyer, along with Pierce v. Society of Sisters (1925), is often cited as one of the first instances in which the U.S. Supreme Court engaged in substantive due process in the area of civil liberties. Substantive due process has since been used as the basis for many far-reaching decisions of the Court, including Roe v. Wade (1972), Planned Parenthood v. Casey (1992), and Lawrence v. Texas (2003).
Next Education Case: Pierce v. Society of Sisters (1925)
Previous Education Case: Dartmouth v. Woodward (1818)
Previous Case: Adkins v. Children’s Hospital (1923)