Meyer v. Nebraska

Meyer v. Nebraska
Argued February 23, 1923
Decided June 4, 1923
Full case nameRobert T. Meyer v. State of Nebraska
Citations262 U.S. 390 (more)
43 S. Ct. 625; 67 L. Ed. 1042; 1923 U.S. LEXIS 2655; 29 A.L.R. 1446
Case history
PriorJudgment for respondent, Meyer v. State, 107 Neb. 657, 187 N.W. 100 (1922).
Holding
A 1919 Nebraska law prohibiting the teaching of modern foreign languages to grade-school children violated the Due Process Clause of the 14th Amendment.
Court membership
Chief Justice
William H. Taft
Associate Justices
Joseph McKenna · Oliver W. Holmes Jr.
Willis Van Devanter · James C. McReynolds
Louis Brandeis · George Sutherland
Pierce Butler · Edward T. Sanford
Case opinions
MajorityMcReynolds, joined by Taft, McKenna, Van Devanter, Brandeis, Butler, Sanford
DissentHolmes, joined by Sutherland
Laws applied
U.S. Const. amend. XIV

Meyer v. Nebraska, 262 U.S. 390 (1923), was a landmark decision by the United States Supreme Court that held that the "Siman Act", a 1919 Nebraska law prohibiting minority languages as both the subject and medium of instruction in schools, violated the Due Process Clause of the Fourteenth Amendment to the United States Constitution.[1] The Court's ruling is one of the earliest articulations of substantive due process.[2]

The Siman Act had been passed after World War I as part of the English only movement and during a time of pervasive anti-German sentiment, atrocity propaganda, and spy scare paranoia promoted by U.S. news media. Nebraska was one of 22 states that had enacted laws banning or restricting foreign language instruction based on broader nativist sentiments to promote assimilation into American culture and society.[3]

The Supreme Court, while recognizing that states have significant power to "make reasonable regulations for all schools", invalidated the Siman Act as an excessive "interference" of liberties granted by the Fourteenth Amendment, such as the right of a teacher to instruct students and the right of parents to control the upbringing of their children.[4] The Court also noted that such rights extend broadly to all Americans, including those who speak foreign languages.[4]

Meyer has been described by legal scholars as "the case that defined personal liberties"[3] and "America's First Privacy Case",[5] since it greatly expanded the scope of constitutionally protected liberties to include both enumerated and unenumerated "fundamental rights" such as the right "to contract, to engage in any of the common occupations of life, to acquire useful knowledge, [and] to marry, establish a home and bring up children...".[6] This subsequently developed into the legal principle of substantive due process that would underpin decisions related to same-sex marriage, racial discrimination, and reproductive rights.[2][3]

  1. ^ Meyer v. Nebraska, 262 U.S. 390 (1923).
  2. ^ a b The Little-Remembered Supreme Court Precedent That Could Protect IVF — and Abortion POLITICO (March 27, 2024)
  3. ^ a b c "A Century of Meyer v. Nebraska: The SCOTUS Case that Defined Personal Liberties". www.jurist.org. June 2, 2023. Retrieved December 27, 2023.
  4. ^ a b Page 262 U.S. 401.
  5. ^ SCARINCI, DONALD (April 16, 2015). "America's First Privacy Case: Meyer v. State of Nebraska". Constitutional Law Reporter. Retrieved December 27, 2023.
  6. ^ Page 262 U.S. 399