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Pierce v. Soc'y of Sisters - 268 U.S. 510, 45 S. Ct. 571 (1925)Rule:Legislation may not unreasonably interfere with the liberty of parents and guardians to direct the upbringing and education of children under their control. Rights guaranteed by the U.S. Constitution may not be abridged by legislation which has no reasonable relation to some purpose within the competency of the state. Facts:The Society of Sisters was an Oregon corporation organized in 1880 with the power to care for orphans, educate and instruct the youth, establish and maintain academies or schools, and acquire necessary real and personal property. In 1922, Oregon adopted the Compulsory Education Act (Act), which became effective in 1926. Under the aforementioned statute, every parent, guardian or other person having control or charge or custody of a child between eight and sixteen years was required to send the child to a public school for the period of time a public school shall be held during the current year in the district where the child resided. Failure to do so was declared a misdemeanor. The manifest purpose was to compel general attendance at public schools by normal children, between eight and sixteen, who had not completed the eighth grade. Acting based on the assertion that the statute impaired the profitable features of its business, the Society of Sisters filed actions against appellant public officials, challenging the constitutionality of the Act under the Fourteenth Amendment and seeking to enjoin enforcement of the Act. The district court entered an order enjoining the public officials from enforcing the Act. They sought review. Issue:Was the Compulsory Education Act valid? Answer:No. Conclusion:The United States Supreme Court affirmed the order enjoining public officials from enforcing the Act. It held that the inevitable practical result of enforcing the Act was the destruction of the Society of Sisters' primary schools and perhaps all other private primary schools for normal children within the state. According to the Court, the Act unreasonably interfered with the liberty of parents and guardians to direct the upbringing and education of their children. Although the Society of Sisters was a corporation, it could claim constitutional protection for its business and property, it sought protection against a present and real threat of injury from the arbitrary, unreasonable, and unlawful interference with their patrons. An injunction was an appropriate remedy to prevent the present threat of irreparable harm and thus, the court held that injunctive relief was proper. Following is the case brief for Pierce v. Society of Sisters, 268 U.S. 510 (1925) Case Summary of Pierce v. Society of Sisters:
Pierce v. Society of Sisters Case BriefStatement of the Facts: The State of Oregon enacted the Compulsory Education Act in 1922. The Act requires any person with custody of a child between the ages of eight and sixteen to send the child to a public school in the district where the child resides. Appellees, two private corporations named the Society of Sisters and Hill Military Academy, provided private education to the children of Oregon. Both appellees sought to enjoin enforcement of the Act. The Society of Sisters argued that the Act intrudes on parents’ right to have their children educated in a school of their choice. Hill Military Academy argued that the Act violates the Fourteenth Amendment’s prohibition against taking property without due process of law. Both schools claimed that the Act would cause irreparable injury to their businesses. Procedural History:
Issue and Holding: Can a state government compel parents to send their children to public school? No. Judgment: The judgment of the District Court is affirmed. Rule of Law or Legal Principle Applied: A state government cannot compel children to attend public school because doing so would infringe on a parent’s choice of how his/her child will be educated and would improperly interfere with the businesses of private schools. Reasoning: First, there is no indication that the private schools run by appellees are harmful, but rather are useful and meritorious. Enforcement of the Act would lead to the destruction of those private schools. Nothing stops the State of Oregon, or any state, from regulating private schools to ensure quality. However, a state government cannot use its power to arbitrarily and unreasonably destroy the existence of private schools. Second, it is clear that the Act is an unreasonable interference of a parent’s liberty to direct the upbringing and education of his/her child. Indeed, it is fundamental to liberty that a state government does not have the power to standardize children by making them attend public school. Significance: Pierce v. Society of Sisters established the beginning of the Supreme Court’s expansive view of the due process clause of the Fourteenth Amendment to protect individual liberties and entities other than individuals. Further, this case has been often cited by the Court over the last century to stand as an example of the existence of an implicit right of personal privacy over family matters, see, e.g., Roe v. Wade, 410 U.S. 113, 152 (1973). Student Resources: https://supreme.justia.com/cases/federal/us/268/510/case.html https://www.oyez.org/cases/1900-1940/268us510 https://supreme.justia.com/cases/federal/us/410/113/case.html |
Which of the following was affirmed by the supreme court in pierce v. the society of sisters?
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