The U.S. Supreme Court case Farrington, Governor of Hawaii, et al. v. Tokushige et al., 1926 revolved around the issue of private education and parental rights in choosing their children's education system. The Territory of Hawaii had enacted a law that severely restricted the operation of private schools, particularly those teaching languages other than English or subjects not approved by public school authorities - an act primarily aimed at Japanese language schools due to rising anti-Japanese sentiment during this period. Parents like Matsujiro Tokushige challenged this law as unconstitutional interference with their right to control their children's education. The Supreme Court ruled in favor of Tokushige and others, stating that the law was indeed unconstitutional as it violated parents' fundamental rights to decide on their children’s upbringing and schooling without undue government interference under the Fourteenth Amendment’s Due Process Clause which protects liberty interests including individuals’ rights to establish a home and bring up children.

In the dissenting opinion for Farrington v. Tokushige, Justice Oliver Wendell Holmes Jr., joined by Justices Louis Brandeis and Harlan Fiske Stone, argued that the law in question was a violation of parental rights. They believed that parents should have the right to control their children's education and upbringing without undue interference from the state. The justices also pointed out that there were no compelling reasons given as to why Japanese language schools posed a threat to American society or government. Furthermore, they contended that it was not within the power of Hawaii's legislature nor any other U.S body to decide what languages could be taught in private schools because this would infringe upon personal liberties protected under due process clause of Fourteenth Amendment.