Bartels v. Iowa

Background

These consolidated cases involved teachers and schools in Iowa, Ohio, and Nebraska who were prosecuted or threatened under state laws that required English as the medium of instruction and banned teaching other languages to pupils below the eighth grade. One teacher was convicted in Iowa for teaching young parochial-school pupils to read German, two teachers in Ohio were convicted for similar German instruction, and Nebraska officials sought to enforce a law making English the official language and forbidding foreign-language instruction to early-grade students.

Reasoning

The Court reversed the state supreme court judgments in each case, doing so “upon authority of Meyer v. Nebraska,” decided the same day. The central legal question was whether states could criminally prohibit teaching languages other than English to children who had not completed the eighth grade. The majority applied the rule announced in Meyer and held that the challenged statutes could not stand, so the convictions and the enforcement posture below were overturned.

Real world impact

As a result, the convictions and injunction denials tied to these English-only statutes were reversed, which prevents those particular state laws from being enforced against teachers and schools in these cases. The ruling affects public, private, and parochial instruction practices in the states involved and means teachers may not be criminally punished under the statutes described.

Dissents or concurrances

Justice Holmes dissented, arguing that requiring English instruction for very young children could be a reasonable way to promote a common language, and he would not categorically forbid such experiments in certain local circumstances.