In the 1922 case of Bartels v. State of Iowa, the U.S. Supreme Court ruled in favor of a German-language private school teacher who was convicted under an Iowa law that prohibited foreign language instruction to students until they had completed eighth grade. The court held that this law violated the Due Process clause of the Fourteenth Amendment as it interfered with parents' rights to control their children's education and infringed upon individual liberties without sufficient justification from the state. This ruling established important precedent regarding parental rights in education and limitations on state power over educational practices.

In the dissenting opinion for Bartels v. State of Iowa, it was argued that the majority's decision violated the defendant's constitutional rights under both state and federal law. The dissenters believed that Bartels' conviction on charges of sedition was based on an overly broad interpretation of a state statute which criminalized certain types of speech during wartime. They contended this interpretation infringed upon his First Amendment right to free speech as well as similar protections provided by Iowa’s constitution. Furthermore, they disagreed with the majority's assertion that such restrictions were justified in times of war, arguing instead that these fundamental rights should not be curtailed even in extraordinary circumstances. In their view, upholding Bartels' conviction set a dangerous precedent for future cases involving freedom of expression and could potentially lead to further erosion of civil liberties.