Lau v. Nichols

Identification U.S. Supreme Court decision

Date Decided on January 21, 1974

The Supreme Court’s unanimous ruling established educational rights for non-English-speaking students and mandated that school districts with a large number of pupils who speak little or no English must provide special language and education instruction so as not to deny those students access to an equal opportunity for a meaningful education.

Kinney Kinmon Lau and twelve other non-English-speaking pupils filed a lawsuit in U.S. District Court in March, 1970, on behalf of nearly three thousand Chinese-speaking students. The plaintiffs alleged that San Francisco school board president Alan Nichols and other officials failed to create adequate programs in the city’s school district that would allow recent immigrant Chinese children to receive special instruction in the English language. School officials responded that even with federal Health, Education, and Welfare (HEW) Department monies and state financial assistance, San Francisco’s school board was obligated to provide for only about 30 percent of Chinese-speaking students to get special bilingual-language instruction because of insufficient funds and few Chinese-speaking teachers.

Both the U.S. District Court and the Ninth Circuit Court of Appeals ruled that Lau’s claims of discrimination did not amount to a violation of the Civil Rights Act of 1964 or the Fourteenth Amendment. These decisions meant that the San Francisco schools’ responsibility did not go beyond that of providing Chinese students with the same facilities, textbooks, teachers, and teaching materials that it provided to other children.

Because of the public importance of this issue, however, the U.S. Supreme Court granted review. On January 21, 1974, the U.S. Supreme Court ruled that students who are not proficient in the English language are denied an opportunity for a meaningful education. California policy required all school districts to ensure the mastery of English by their pupils. Therefore, the Court argued that if Chinese-speaking students do not understand English, then equal treatment is not occurring in the classroom simply by providing the same teachers, texts, and curriculum. Denial of a meaningful opportunity to participate in the educational program is discrimination banned by section 601 of the Civil Rights Act and HEW guidelines that prohibit racial discrimination in federally assisted San Francisco schools. Affirmative steps were required to reach language proficiency. The Lau case was sent back to the federal district court, and the district judge ruled that a suitable remedy to the case was bilingual education.

Impact

Because of the Lau decision and subsequent court rulings and state legislative enactments during the 1970’s, nearly 360 American school districts chose or were pressured to introduce bilingual, bicultural, or English-immersion programs to meet the needs of limited-English-speaking students. Moreover, in 1975, the Voting Rights Act was amended to require the use of bilingual ballots in areas of certain states with high percentages of limited-English-speaking voters.

Bibliography

Crawford, James. Bilingual Education: History, Politics, Theory, and Practice. 3d ed. Los Angeles: Bilingual Educational Service, 1995.

McPherson, Stephanie. Lau v. Nichols: Bilingual Education in Public Schools. Berkeley Heights, N.J.: Enslow, 2000.

Wang, Ling-Chi. “Lau v. Nichols: History of a Struggle for Equal and Quality Education.” In The Asian American Educational Experience: A Source Book for Teachers and Students, edited by Don T. Nakanishi and Tina Nishida. New York: Routledge, 1995.