Pierce v. Society of Sisters

Supreme Court of United States
268 U.S. 510 (1925)

ELI5:

Rule of Law:

A state law compelling all children to attend public schools is an unconstitutional infringement upon the liberty of parents and guardians to direct the upbringing and education of their children, as protected by the Due Process Clause of the Fourteenth Amendment.

Facts:

In November 1922, the voters of Oregon enacted the Compulsory Education Act, which mandated that children between the ages of eight and sixteen attend public schools.
The Society of Sisters of the Holy Names of Jesus and Mary, an Oregon corporation, operated private schools and orphanages offering both secular and religious (Roman Catholic) instruction.
The Hill Military Academy, another Oregon corporation, operated a private military, elementary, and college preparatory school for profit.
Both the Society of Sisters and the Hill Military Academy owned substantial property and depended on tuition fees and long-term contracts with parents for their continued operation.
Following the passage of the Act, which was set to take effect in 1926, parents began withdrawing children from these private schools and refused to enter into future contracts.
The Act's existence and the state's announced intention to enforce it threatened to destroy the business and property of both private school corporations by eliminating their student base.

Procedural Posture:

The Society of Sisters and the Hill Military Academy each filed suit in the U.S. District Court for the District of Oregon against Governor Walter M. Pierce and other state officials.
The schools sought preliminary injunctions to restrain the state from enforcing the Compulsory Education Act.
The cases were heard by a three-judge panel of the federal district court.
The District Court granted the preliminary injunctions, ruling that the Act was unconstitutional.
The State of Oregon (appellants) appealed the District Court's decision directly to the Supreme Court of the United States.

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Issue:

Does a state law requiring every parent or guardian to send their child between the ages of eight and sixteen to a public school unreasonably interfere with the liberty of parents to direct their children's education and with the property rights of private schools in violation of the Fourteenth Amendment's Due Process Clause?

Opinions:

Majority - Justice McReynolds

Yes. The Compulsory Education Act of 1922 unreasonably interferes with the liberty of parents and guardians to direct the upbringing and education of children under their control, which is a fundamental right protected by the Fourteenth Amendment. The Court reasoned that the state's power to regulate education is not absolute and does not include the authority to standardize children by forcing them to accept instruction only from public school teachers. Citing Meyer v. Nebraska, the Court affirmed that the liberty protected by the Due Process Clause extends beyond freedom from bodily restraint to include the right of parents to guide their children's intellectual and moral development. While the private schools, as corporations, cannot claim this personal liberty for themselves, they can seek protection for their business and property interests, which were threatened with destruction by the state's unlawful compulsion upon their present and prospective patrons.

Analysis:

This landmark decision firmly established a parent's fundamental constitutional right to direct their child's education under the doctrine of substantive due process. It secured the place of private and religious schools in American education by preventing states from monopolizing schooling. The case's broad interpretation of 'liberty' under the Fourteenth Amendment became a crucial precedent for later decisions recognizing rights related to family autonomy and privacy, such as Griswold v. Connecticut and Roe v. Wade. It demonstrates that the state's police power, while broad, is not unlimited and cannot be used to abridge fundamental personal liberties without a reasonable relation to a legitimate state purpose.

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