Wisconsin Vs. Yoder (1972)
Takeaway
Amish children could not be placed under compulsory education past 8th grade. The parents' fundamental right to freedom of religion was determined to outweigh the state's interest in educating their children.
Constitutional Connection
1st Amendment, 14th Amendment
Decision
7 - 0 decision; Yoder wins; The Supreme Court ruled that Wisconsin's compulsory school attendance law was unconstitutional because it violated the 1st Amendment right to free exercise of religion.
Remember This!
Parents have the right to keep their children out of public schools for religious reasons.
Background Story
The Amish and Mennonite sects of Christianity view individualism, competition, and self-promotion as vices that separate members from God, one another, and their own salvation. In order to preserve these values, each rural community seeks to become largely self-sufficient, providing for its members' needs with minimal support from those outside the community. These beliefs led many communities to stop formal education, in the form of public, private, or home schooling, for their children after the age of 14. In the mid-20th century, many US states raised the age to which children must attend school, and that created conflict with the Amish and Mennonite practices.
Reasoning
The Supreme Court held that the Free Exercise Clause of the First Amendment prevented the state of Wisconsin from compelling families to send their children to formal secondary school beyond the age of 14. The Supreme Court stated that the requirement to send children to school beyond eighth grade would interfere with well-established religious convictions. The Supreme Court rejected the state's arguments for overriding the parents' religious beliefs. The Supreme Court commented that an additional one or two years of high school would not produce enough educational benefits for the Amish to constitute a "compelling government interest." The Supreme Court cited the endurance of their law-abiding community for centuries as evidence that the Amish meet the responsibilities of citizenship without the required additional years of education.
Case Facts
The state of Wisconsin convicted three members of Old Order Amish and Mennonite communities for violating the state's compulsory education law. Yoder and two other students had stopped attending school at the end of 8th grade. The Amish claimed that their religious faith and mode of life are inseparable and interdependent. They believe that exposure to competitive pressures of formal schooling, the content of higher learning, and removal from their religiously infused practices of daily life will endanger children's salvation, the parents' own salvation, and the continuation of the Amish community. The Amish community provides an alternative education that adequately prepares children for their adult roles within their community.
Definitions
○ 1st Amendment - Free Exercise Clause • Protects the citizens' right to practice their religion as long as the practice does not run into conflict with public morals or governmental interest. ○ Wisconsin's Compulsory Education Law • Requires attendance at school until the age of 16.
