In the 1922 case of Meyer v. State of Nebraska, the United States Supreme Court ruled that a Nebraska law restricting foreign language education violated the Due Process clause of the Fourteenth Amendment. The law in question prohibited teaching any modern language other than English to students who had not passed eighth grade. Robert T. Meyer, a teacher at Zion Parochial School, was convicted under this statute for teaching German to a ten-year-old student and fined $25. In its decision, the court held that while states have power to prescribe school curriculum, they cannot infringe upon certain fundamental rights such as those protected by the Fourteenth Amendment including liberty interests in acquiring useful knowledge and preparing individuals for professional careers.

In the dissenting opinion for Meyer v. State of Nebraska, Justice James C. McReynolds disagreed with the majority's decision to strike down a Nebraska law prohibiting foreign language instruction for children who had not yet passed eighth grade. He argued that states should have broad authority to regulate education and protect public safety, health, and morals without interference from federal courts unless there is clear violation of constitutional rights. In his view, it was within the state’s power to determine what constitutes proper educational standards in order to promote assimilation and unity among its citizens. The statute did not infringe upon any specific prohibition in the Constitution nor deprive individuals of liberty or property without due process; rather it was an exercise of police power aimed at promoting common understanding through use of English language which he believed necessary for good citizenship.