Wisconsin v. Yoder
"Wisconsin v. Yoder" is a significant Supreme Court case that addressed the intersection of state education mandates and the First Amendment rights of religious groups. The case arose from Wisconsin's compulsory school-attendance law, which required children to attend school until age sixteen. The Old Order Amish community opposed education beyond the eighth grade, believing it conflicted with their values and way of life. In this context, Amish parents Jonas Yoder and another parent were convicted for failing to comply with the law. The Supreme Court ruled in a 6-1 decision that the application of the law against Amish parents infringed upon their religious freedoms. Chief Justice Warren E. Burger highlighted the importance of protecting long-standing religious traditions while recognizing the state's interest in education. The ruling indicated that educational laws cannot impose undue burdens on religious practices, a principle rooted in prior cases. Although this decision established a precedent for balancing state interests with religious freedom, subsequent rulings have raised questions about its enduring applicability.
Wisconsin v. Yoder
Date: May 15, 1972
Citation: 406 U.S. 205
Issue: Freedom of religion
Significance: Using the compelling interest standard, the Supreme Court held that a state could not require the children of some religious sects to attend high school.
Wisconsin’s compulsory school-attendance law required children to attend public or private schools until the age of sixteen. The Old Order Amish Church was opposed to formal education beyond the eighth grade because such an environment promotes secular and competitive values contrary to the Amish way of life. After the eighth grade, however, Amish parents did provide additional career training and religious instruction in private homes. Jonas Yoder and another Amish parent were convicted and fined five dollars each for violating the law.
By a 6-1 margin, the Supreme Court found that application of the law to Amish parents was prohibited by the free exercise clause of the First Amendment. Writing for the Court, Chief Justice Warren E. Burger balanced the free exercise claims of the parents against the state’s competing interest in educating children. Although the state’s interest in education was of “the highest order,” it was not absolute to the exclusion of all other interests. Burger emphasized the long history of Amish traditions and that the Amish alternative to education prepared young people to function effectively in later life. Referring to Sherbert v. Verner (1963), he noted that a law neutral on its face could be unconstitutional if it placed an undue burden on the free exercise of one’s religious beliefs. Dissenting in part, Justice William O. Douglas wrote that the children themselves should have the choice of deciding whether or not to attend high school. In Employment Division, Department of Human Resources v. Smith (1990), the Court rejected the compelling interest standard in cases dealing with indirect burdens on religious conduct; thus, it is unclear whether Yoder continues as a binding precedent.