In the 1924 case of Samuels v. McCurdy, Sheriff of DeKalb County, Georgia, the U.S Supreme Court addressed a dispute involving an alleged violation of due process rights under the Fourteenth Amendment. The plaintiff was arrested and detained without being given a hearing or trial after he failed to pay fines related to violations of local prohibition laws in DeKalb County. He argued that his detention violated his constitutional right to due process because he had not been afforded an opportunity for a fair hearing before being deprived of his liberty. The court ruled in favor of Samuels, holding that even though states have broad powers to enforce their own laws and regulations within their jurisdictional boundaries, they must still respect individuals' fundamental procedural rights as guaranteed by the Constitution's Due Process Clause when doing so.

In the dissenting opinion for Samuels v. McCurdy, Justice Oliver Wendell Holmes Jr., disagreed with the majority's decision to overturn a Georgia law that prohibited teaching foreign languages to children until they had passed eighth grade. He argued that it was within the state's rights to regulate education in this manner as part of its police power and responsibility towards public welfare. Holmes believed that states should have broad discretion in determining what constitutes proper education, including language instruction policies. He also suggested that there might be legitimate reasons for delaying foreign language instruction, such as ensuring students first master English or preventing potential disloyalty from immigrant populations during times of war.