Wisconsin v. Yoder
406 U.S. 205 (1972)
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Rule of Law:
The First Amendment's Free Exercise Clause prevents a state from compelling Amish parents to send their children to formal high school until age 16. The state's interest in universal education is not absolute and must yield to the parents' fundamental right to freedom of religion when the religious practice is deeply rooted, sincere, and not harmful to the child or society.
Facts:
- Jonas Yoder, Wallace Miller, and Adin Yutzy were members of the Old Order Amish and Conservative Amish Mennonite Church in Green County, Wisconsin.
- Their religious beliefs mandate a life separate from worldly influences and centered on an agrarian, church-based community.
- They believe that formal high school education exposes children to values such as competition, materialism, and intellectualism, which are contrary to Amish faith and way of life.
- This exposure during the formative adolescent years is believed to endanger the salvation of the children and the parents, and threaten the survival of the Amish community.
- In accordance with these beliefs, the parents declined to send their children, ages 14 and 15, to public or private school after they completed the eighth grade.
- Wisconsin's compulsory school attendance law required children to attend school until the age of 16.
- The State of Wisconsin stipulated that the parents' religious beliefs were sincere.
- The Amish provide an alternative, informal vocational education for their adolescent children, designed to prepare them for adult roles within the Amish community.
Procedural Posture:
- Jonas Yoder, Wallace Miller, and Adin Yutzy were charged, tried, and convicted in Green County Court (trial court) for violating Wisconsin's compulsory school attendance law and were fined $5 each.
- The respondents appealed their convictions to the Wisconsin Circuit Court (intermediate appellate court), which affirmed the convictions.
- The respondents then appealed to the Wisconsin Supreme Court (state's highest court).
- The Wisconsin Supreme Court reversed the convictions, holding that the law, as applied to the respondents, violated their rights under the Free Exercise Clause of the First Amendment.
- The State of Wisconsin, the petitioner, sought and was granted a writ of certiorari by the Supreme Court of the United States to review the decision of the Wisconsin Supreme Court.
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Issue:
Does applying Wisconsin's compulsory school attendance law to Amish parents who refuse to send their children to school after the eighth grade, based on sincere religious beliefs, violate their rights under the Free Exercise Clause of the First Amendment?
Opinions:
Majority - Chief Justice Burger
Yes. Applying Wisconsin's compulsory school attendance law to the respondents violates their rights under the Free Exercise Clause. The Court found that the Amish way of life is not merely a personal preference but is inseparable from their deeply held religious beliefs, which have a 300-year history. Forcing Amish children into a high school environment, with its emphasis on values contrary to Amish faith, imposes a severe burden on the free exercise of their religion and threatens the very existence of their community. The state's interest in universal education, while compelling in general, is not sufficiently compelling to override this fundamental right in this specific context. The evidence showed that the Amish alternative of vocational training prepares children to be self-sufficient and law-abiding members of society, thereby satisfying the state's core educational interests without infringing on religious freedom.
Concurrence - Justice Stewart
Yes. This case concerns the criminal punishment of parents for following their religious beliefs, which Wisconsin cannot constitutionally do. The concurrence emphasizes that the case does not present the question of a child's right to attend school against their parents' wishes, as the record indicates the children's religious beliefs were aligned with those of their parents. The interesting issue raised by the dissent concerning a potential conflict between parent and child is not present on this record.
Concurrence - Justice White
Yes. Although the case presents a close and delicate balance of competing interests, the respondents' claim must prevail. This conclusion is based on the fact that the Amish permit basic education through eighth grade and the deviation from state law is relatively slight (one to two years). The state's valid interest in developing the potential of its children is not sufficient to overcome the sincere religious practice, especially since the state failed to demonstrate that Amish children would be intellectually stultified or unable to acquire new skills later in life if they chose to leave their community.
Dissenting - Justice Douglas
The case should be remanded. The Court's analysis improperly ignores the independent constitutional interests of the children. A child is a 'person' under the Constitution and possesses First Amendment rights, including the right to choose their own educational and religious path. To allow the parents a religious exemption imposes their beliefs upon the child, who may hold conflicting desires. The views of the children involved in the cases of Adin Yutzy and Wallace Miller were never canvassed. Therefore, while the judgment for Jonas Yoder (whose daughter testified in agreement with him) could be affirmed, the other cases should be remanded to determine the children's wishes.
Analysis:
This landmark decision solidified the application of the compelling interest test from Sherbert v. Verner to a neutral law of general applicability that substantially burdens a religious practice. By carving out an exemption to compulsory education laws, the Court elevated the fundamental right of parents to direct the religious upbringing of their children, particularly when combined with a Free Exercise claim. The holding is narrow, however, relying heavily on the unique, centuries-old, and self-sufficient nature of the Amish community, making it difficult for other groups to make a similar claim. The case represents a high-water mark for judicial protection of religious exemptions under the Free Exercise Clause.
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