Minersville School District v. Gobitis

Minersville School District v. Gobitis
Supreme Court of the United States
Argued April 25, 1940
Decided June 3, 1940
Full case nameMinersville School District, Board of Education of Minersville School District, et al. v. Walter Gobitis, et al.
Citations310 U.S. 586 (more)
60 S. Ct. 1010; 84 L. Ed. 1375; 1940 U.S. LEXIS 1136; 17 Ohio Op. 417; 127 A.L.R. 1493
Case history
PriorJudgment for plaintiffs, injunction granted, 24 F. Supp. 271 (E.D. Pa. 1938); affirmed, 108 F.2d 683 (3d Cir. 1939); cert. granted, 309 U.S. 645 (1940).
SubsequentNone
Holding
The First Amendment does not require States to excuse public school students from saluting the American flag and reciting the Pledge of Allegiance on religious grounds. Third Circuit reversed.
Court membership
Chief Justice
Charles E. Hughes
Associate Justices
James C. McReynolds · Harlan F. Stone
Owen Roberts · Hugo Black
Stanley F. Reed · Felix Frankfurter
William O. Douglas · Frank Murphy
Case opinions
MajorityFrankfurter, joined by Hughes, McReynolds, Roberts, Black, Reed, Douglas, Murphy
DissentStone
Laws applied
U.S. Const. amends. I, XIV
Overruled by
West Virginia State Board of Education v. Barnette, 319 U.S. 624 (1943)

Minersville School District v. Gobitis, 310 U.S. 586 (1940), was a decision by the Supreme Court of the United States restricting the religious rights of public school students under the First Amendment to the United States Constitution. The Court ruled that public schools could compel students—in this case, Jehovah's Witnesses—to salute the American flag and recite the Pledge of Allegiance despite the students' religious objections to these practices.[1] This decision led to increased persecution of Witnesses in the United States. The Supreme Court overruled this decision three years later in West Virginia State Board of Education v. Barnette (1943).[2]

Subsequent cases have applied a lower standard of review to generally applicable laws when evaluating free exercise claims;[3] Justice Antonin Scalia cited Frankfurter's Gobitis opinion at least three times in Employment Division v. Smith (1990).[4]

  1. ^ Minersville School District v. Gobitis, 310 U.S. 586 (1940).
  2. ^ West Virginia State Board of Education v. Barnette, 319 U.S. 624 (1943).
  3. ^ Hall, Daniel E. (2022). Criminal Law and Procedure. Cengage. p. 263. The Supreme Court issued an important decision concerning the standard of review in Free Exercise cases in Department of Human Resources v. Smith...reversing an earlier decision, the Court decided that a neutral law of general applicability is to be reviewed under the Rational Basis Test, not strict scrutiny.
  4. ^ McThenia, Andrew (2007). Radical Christian and Exemplary Lawyer. Wipf and Stock. p. 144.