Meyer v. Nebraska, 262 U.S. 390 (1923) (Supreme Court of the United States)
Meyer v. Nebraska is a foundational Fourteenth Amendment substantive due process case that broadened the constitutional understanding of liberty beyond mere freedom from physical restraint.
Does a state law that prohibits teaching modern foreign languages to young students and forbids instruction in languages other than English for those students violate the liberty protected by the Due Process Clause of the Fourteenth Amendment?
The Fourteenth Amendment's Due Process Clause protects liberty interests that include, among other things, the rights of parents to direct the upbringing and education of their children, the right of teachers to engage in their common occupation, and the right of students to acquire useful knowledge. While a state may regulate schools and curricula pursuant to its police power, any regulation must bear a reasonable relation to a legitimate state objective and may not arbitrarily or unreasonably interfere with protected liberty interests.
Yes. Nebraska's prohibition on foreign-language instruction for young students unconstitutionally infringes the liberty protected by the Fourteenth Amendment because it is an arbitrary and unreasonable means of pursuing the state's asserted aims.
Meyer marks a seminal articulation of substantive due process under the Fourteenth Amendment, placing parental control of education, teachers' occupational liberty, and students' pursuit of knowledge within the ambit of protected liberty. It limited state police power where regulations are arbitrary or unrelated to legitimate ends. Together with Pierce v. Society of Sisters (1925), Meyer anchors the constitutional protection of family autonomy and educational choice, later informing cases involving privacy, family relations, and decisional autonomy. For law students, Meyer is essential for understanding the evolution of substantive due process, the scope of liberty beyond economic rights, and the analytical requirement that state regulations bear a reasonable relation to valid purposes.