What religious clause was used in Wisconsin v Yoder what were the facts of the case and what was the ruling of the Court?

Synopsis of Rule of Law. The law compelling parents to send their children to public school until the age of 16 is unconstitutional as applied because it impermissibly interferes with the Amish religious beliefs.

Facts. Respondents Jonas Yoder, Wallace Miller, and Adin Yutzy are members of the Amish religion. Wisconsin’s compulsory school-attendance law required them to cause their children to attend public or private school until they reach 16. Respondents declined to send their children to public school after completion of the eighth grade. Respondents were convicted of violating the law and fined $5 each.

Issue. Did the application of the compulsory attendance law violate respondent’s rights under the First and Fourteenth Amendments to the United States Constitution?

Held. The application of the law is unconstitutional as applied to the Amish.
The Amish object to the high school education because the values taught there are in marked variance from the Amish values and way of life. It places Amish children in an environment hostile to their beliefs and takes them away from their community during a crucial period in their life. The Amish do not object to elementary education. Expert Dr. Hostetler testified that the compulsory attendance could result in not only great psychological harm to Amish children but ultimately the destruction of the Old Order Amish church community.

The State has the power to impose reasonable regulations for the control and duration of basic education. Previous precedent has held that this power must yield to the right of parents to provide an equivalent education in a privately operated system. The State’s power is subject to a balancing test when it impinges on fundamental rights such as those protected by the Free Exercise Clause of the First Amendment and the traditional interest of parents with respect to the religious upbringing of their children.

In order for Wisconsin to compel such attendance, it must follow that either the State does not deny the free exercise of religious belief by its requirement or that there is a state interest of sufficient magnitude to override the interest claiming protection under the Free Exercise Clause. This Court determines that the Amish objection to the attendance is rooted in religious beliefs that directly conflict with the compulsory school attendance law.

The State advances two arguments. First, it notes that some degree of education is necessary to prepare citizens to participate effectively and intelligently in our open political system. Second, education prepares individuals to be self-reliant and self-sufficient participants in society. We accept these propositions. However, the evidence adduced shows that an additional one or two years of formal high school would do little to serve those interests. Such education may be necessary for preparation for the modern society in which we live, but is not for the separated agrarian community of the Amish faith.

The State attacks respondents’ position as fostering ignorance from which children must be protected by the State. However, the record shows that the Amish community has been a highly successful social unit within our society, producing productive and law-abiding citizens. The State also supports its position on the possibility that some children will choose to leave the Amish community. This argument is highly speculative on the record, and the practical agricultural training and habits of industry would support children that did choose to leave.

The requirement for compulsory high school education is a fairly recent development, designed to not only provide educational opportunities, but also to avoid child labor or forced idleness. In these terms, Wisconsin’s interest in compelling school attendance is less substantial for Amish children than for children generally.

The State finally argues that exempting the Amish children fails to recognize the children’s substantive right to a secondary education, giving due regard to the power of the State as parens patriae. On this record there is no need to decide an issue in which the Amish parent’s are preventing children who wish to further their education from attending school.

Dissent. The majority assumes that the interests at stake are only those of the parents and the State. The children also have a legitimate interest in their education. The inevitable effect of the decision is to impose the parents’ notions of religious duty upon their children. It is the future of the student, not the parents, that is imperiled by today’s decision. The views of the two children in question were not canvassed, and should be on remand.

Discussion. The majority’s decision did not determine that the statute would violate Constitutional rights if the children wanted to pursue further education, but found that such a decision was unnecessary because no such claim was made on the record. The dissent suggested that the cause should be remanded to determine the desire of the children.

Wisconsin v. Yoder interpreted the Free Exercise Clause by constructing a three-part test intended to balance state educational interests against the interests of religious freedom. This balancing test marked the height of the move away from the belief-action doctrine established in the nineteenth century. The decision also impacted debates regarding parental control of their children's education.

The Free Exercise Clause of the First Amendment has posed a challenge to those courts faced with conflicts between religion and the government. The clause, which protects the free exercise of religion, fails to define religion, leaves its protective parameters unclear, and invites a wide range of interpretations. Interpreting free exercise becomes especially tricky--and especially important--in a culturally diverse nation such as the United States, when members of a religious minority seek exemption from state or federal laws because of their religious beliefs.

In Wisconsin v. Yoder, the Supreme Court grappled with a clash between Amish religious convictions and state educational requirements. Three families belonging to two Amish sects--the Old Amish religion and the Conservative Amish Mennonite Church--refused to send their children to public school past the eighth grade. Though state law required all children to attend school until age 16, the parents of Frieda Yoder, Barbara Miller, and Vernon Yutzy insisted that their religion prohibited them from allowing their children to attend high school. The Amish felt that exposing their children to the mainstream, "worldly" values taught there, such as competition and materialism, would undermine the religious teachings central to their alternative lifestyle and world view. They preferred instead to prepare their children at home for the agricultural and domestic pursuits that awaited them as adults in the Amish community. Therefore they sought exemption from state law under the Free Exercise Clause.

The Court used a three-part test to decide the case. First, it asked whether the religious beliefs in question were sincerely held. Secondly, it asked whether state law did in fact seriously burden those beliefs. After answering in the affirmative to the first two parts, the Court went on to consider the balance of the state's interests against the free exercise interests of the Amish. It determined that in order to rule for the state, state interests had to override religious interests, and that there must be no other way for state interests to be met other than to impinge upon religious freedom. Here the Court found that the state's interest in educating children to be responsible, productive citizens did not override the Amish parents' right to protect their community's religious beliefs by keeping their children out of high school.

The majority opinion emphasized the unique and pervasive nature of the Amish religion in rendering its decision. In an extensive inquiry into Amish religious beliefs and practices, the Court found that in an Amish community, religion, culture and daily life proved inseparable. Removing a child from his or her community for several hours a day thus would seriously undermine religious beliefs. The Court also discussed what it saw as the unbroken historical tradition of the Amish way of life, its isolation, and its rejection of modern conveniences and values. The majority opinion felt that the home-based education provided by the Amish beyond the eighth grade sufficiently prepared their children to function within and contribute to Amish society. The Court even went so far as to say that forcing these parents to send their children to high school threatened the very viability of the Amish religion and way of life.

The decision in Wisconsin v. Yoder brought together two areas of legal interpretation: parental control over education and the free exercise of religion. Between 1923 and 1927 a series of Supreme Court decisions--Meyer v. Nebraska, Pierce v. Society of Sisters, and Farrington v. Tokushige--established parents' constitutional right to exert control over their children's education, though strictly in a secular context. Yoder introduced a religious dimension to that debate.

Yoder also contributed to the Court's long-standing effort to interpret the Free Exercise Clause. In Reynolds v. United States (1879), the Court established the belief-action distinction, which held that though the First Amendment protected religious beliefs, citizens could still be held responsible for actions emanating from those beliefs that violated state or federal laws. In Cantwell v. Connecticut (1940), the Court moved away from strict belief-action doctrine to rule that government could not place an undue burden on religious practice as well as belief. The Court extended free exercise protection to indirect, unintended restrictions on religious practice in Sherbert v. Verner (1963).

In 1972, Wisconsin v. Yoder elaborated on the Sherbert decision, developing the three-part balancing test and issuing what Samuel Brooks called, in a 1990 article for the Valparaiso University Law Review, the Court's "clearest statement of the factors used in analyzing free exercise claims" to date. Together, Sherbert and Yoder seemed thoroughly to renounce the belief-action doctrine of previous rulings. In the 1980s and 1990s, however, the Court rendered several decisions--including United States v. Lee (1982) and Employment Division v. Smith (1990)--that reestablished the belief-action distinction and limited religious exemptions from federal and state laws.

The Supreme Court's decision in Wisconsin v. Yoder elicited mixed reactions. To some, it seemed greatly to extend both constitutional protection of religious freedom and parental control over education. To others, the way in which the Court focused its ruling on the specific facts of the case and emphasized what it saw as the unique nature of the Amish situation, limited its precedential value and actually restricted religious exemptions in future cases. This restrictive aspect has received criticism from several factions, including advocates of parents' rights to protect their children from religiously objectionable portions of school curricula, advocates of complete home education, and those who support private religious schools' freedom from state regulation.

The Yoder decision caused other negative reactions as well. Some critics have faulted the Court for failing to consider the children's interests as distinct from their parents and their right to a lifestyle choice beyond the Amish community. Others have expressed concern with the Court's narrow definition of what kind of religion qualified for the exemption granted in Yoder, a definition that included the existence of an organized group holding common religious convictions and a belief in the literal interpretation of the Bible. Some Native American legal advocates have criticized subsequent courts for misapplying the principles established by Yoder to Native American religions, thus denying Indian people protection of their sacred sites against government use and development. Whether seen as a positive or negative move, it remains clear that far from settling debates over the meaning of the Free Exercise Clause, Wisconsin v. Yoder only added to its multiple interpretations.