Judgments

WISCONSIN VS YODER : CASE SUMMARY

The Supreme Court in Wisconsin Vs Yoder (1972) held that imparting compulsory education beyond 8th grade to Amish children is unconstitutional.

FACTS OF THE CASE

Jonas Yoder and Wallace Miller were members of Old Order Amish Religion and Adin Yutzy was member of the Conservative Amish Mennonite Church.  They were residents of Green Country, Wisconsin. They refused to send their children aged 14 and 15 to any school after 8th grade. Wisconsin’s law required children to attend public or private school until reaching age 16. They were prosecuted and fined under Wisconsin law.

The Wisconsin Circuit Court affirmed the convictions but the Wisconsin Supreme Court reversed the convictions.

OPINION OF THE COURT

Chief Justice Burger delivered the opinion of the Court.

Respondents raised the defense that compulsory attendance laws violated their rights under 1st and 14th Amendment as children’s attendance at public or private school was contrary to Amish religion and way of life. By sending children to school they will face sanction of church and also endanger their salvation.

Amish belief sought to return to early simple Christian life de-emphasizing material success rejecting the competitive spirit and seeking to insulate themselves from the modern world. Amish belief requires members of community to make their living by farming or related activities.

Formal education beyond eighth grade is contrary to Amish beliefs because it places Amish children in competitive environment and puts pressure to confirm to peer group. During this period Amish Children must acquire Amish attitude favoring manual work and self-reliance and the specific skills needed to perform an adult role of an Amish farmer or housewife.

The Supreme Court observed that there is no doubt as to power of State having high responsibility for education of its citizens to impose reasonable regulations for the control and duration of basic education. But State Interest in basic education is not totally free from a balancing process when it impinges upon Fundamental Rights and interests such as those protected by Free Exercise Clause of the First Amendment and traditional interest of parents with respect to religious upbringing of their children so long as they prepare for additional preparations.  Only those interests of highest order and those not otherwise served can overbalance legitimate claims to the free exercise of religion. However strong the State’s interest in universal compulsory education, it is by no means absolute to the exclusion or subordination of all other interests.

The Supreme Court analyzed Amish faith and concluded that secondary education interferes with Amish religious development of Amish child and his integration with Amish way of life.

It was contended by State that some degree of education is necessary to prepare citizens to participate effectively and intelligently in our open political system if we are to preserve freedom and independence. Education prepares individuals to be self-reliant and self-sufficient participants in society.

The Supreme Court observed that it is one thing to say that compulsory education for a year or two beyond the eighth grade may be necessary when its goal is the preparation of child for life in modern society as the majority live, but is quite another if the goal of education be viewed as the preparation of the child for life in the separated agrarian community that is keystone of Amish faith.

The Supreme Court also rejected the argument of State that Amish children have be protected from ignorance. The Supreme Court observed that Amish Community has been a highly successful social unit within society, even if apart from conventional mainstream. Its members are productive and law abiding. They reject public welfare in any of its usual modern forms. Amish are not opposed to education but opposed to formal type of education granted by American schools. There cannot be any assumption that today’s majority is “right” and the Amish and others like them are “wrong”.

The Supreme Court affirmed the decision of Wisconsin Supreme Court.

DISSENTING OPINION OF WILLIAM O. DOUGLAS

Justice William O. Douglas dissented in part. Justice Douglas disapproved the approach of the Court which was only concerned with views of parents and the State. The Court did not consider view of the Amish Children. Children should also be entitled to be heard. A child may be willing to be a pianist or an astronaut or an oceanographer. Such child has to break from Amish tradition for such purposes. Student’s judgment has to be given full meaning. A child should be given opportunity to be heard before giving exemption by State.

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Mukesh Kumar Suman is an advocate and legal author based at Delhi. He regularly appears before various Judicial Forums including NCLT, NCLAT, High Courts and the Supreme Court. He can be approached at mukesh_suman@outlook.com or +91 9717864570.

Mukesh Kumar Suman

Mukesh Kumar Suman

Mukesh Kumar Suman is an advocate based at Delhi. He has rich experience in civil, criminal, commercial, arbitration and corporate insolvency matters. He regularly appears before District Courts, NCLT, NCLAT, High Court and the Supreme Court. He can be approached at mukesh_suman@outlook.com or +91 9717864570.

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