Wisconsin v. Yoder

The Free Excercise Clause in the First Amendment protects citizens from acts of Congress that do not allow them to exercise religion freely. But what happens when the First Amendment granting individual liberties infringes on the state's interests and social order? The Wisconsin v. Yoder case put that question to the test.

Figure 1. State's Interests vs. First Amendment, StudySmarter Originals

Wisconsin v Yoder Summary

The Wisconsin v. Yoder case originated in New Glarus county in Wisconsin. It involved three Amish children and their parent's refusal to enroll them in school after the 8th grade for religious reasons. The state of Wisconsin saw this as a violation of their compulsory-attendance law, which stated that children had to go to school until they were 16, and sued the parents. The lower courts sided with the school district. However, it was appealed, and the Supreme Court of Wisconsin voted in favor of Yoder, stating that the state of Wisconsin was violating the First Amendment free exercise of religion clause in forcing the Amish children to go to school. The state of Wisconsin appealed, and the trial went to the Supreme Court.

On May 15, 1972, the Supreme Court unanimously ruled in favor of Yoder and essentially agreed with the Wisconsin Supreme Court that the state of Wisconsin forcing the Amish to go to school after the 8th grade violated their freedom of religion rights under the 1st Amendment.

Wisconsin v. Yoder Facts

The facts of this case are:

• 3 Amish families were convicted and fined $5 for violating the Wisconsin compulsory attendance law.
• The Compulsory attendance law forced children to go to school until they were 16 years old.
• The Amish families argued that going to school after 8th grade violated the First Amendment because their children going to school affected their assimilation into the Amish community and prevented their salvation.
• The trial and circuit courts voted in favor of the state of Wisconsin, while both the state Supreme Court and the federal Supreme Court voted in favor of Yoder.

Figure 2. Amish Man Working, Joe Schneid, CC-BY-3.0, Wikimedia Commons

Wisconsin v. Yoder 1972

In 1971 Jonas Yoder, Wallace Miller, and Adin Yutzy, the parents of Freida Yoder, 15; Barbara Miller, 15; and Vernon Yutzy, 14, were convicted and fined $5 for not enrolling their kids in school after the 8th grade, in accordance with the state's compulsory attendance law. This law required all citizens in the state of Wisconsin to go to school until the age of sixteen.

The parents of the children involved were part of the Amish Community; Jonas Yoder and Wallace Miller were part of Old Order Amish Church, and Adin Yutzy was a part of the Conservative Amish Mennonite Church. Being Amish, they believed that schooling beyond 8th grade in a public setting was not suitable for their children because they would learn more from vocational training provided by the community than they would at school. They also argued that allowing their children to continue their education until they were 16 would damage their children's religious values and prevent them from receiving salvation. Therefore, they believed that the state of Wisconsin was violating their rights under the Free Exercise Clause of the First Amendment.

The trial and circuit courts ruled in favor of the state of Wisconsin. However, the state Supreme Court, on the other hand, sided with Yoder stating that establishing an education system doesn't override the right to exercise religious freedom. The state of Wisconsin then appealed, and the Supreme Court heard the case on December 8, 1971. On May 15, 1972, the court made its ruling.

Figure 3. Inside of Supreme Court, Phil Roeder, CC-BY-2.0, Wikimedia Commons

Wisconsin v Yoder Ruling

On May 15, 1972, the Supreme Court unanimously voted in favor of Yoder and agreed that the Wisconsin compulsory attendance law violated the Amish's First Amendment right to exercise their religion freely.

To make a ruling, the court used a three-part test to determine if the actions of the government violated the Exercising Freedom Clause:

1. Are the religious beliefs sincere?
2. Does the governmental law burden those beliefs?
3. Does the religious solution provide an adequate substitution for what the government is requiring?

In a majority opinion written by Chief Justice Warren E. Burger, he responds to these questions. He stated that the Amish religion was sincere because, throughout its history, they have shown the validity and simplicity of their Christian values. The Chief Justice remarked that since the Amish rejected the modern, secular world, having their children attend classes beyond the eighth grade would result in the undermining of the Amish religion and their way of life. The majority opinion also argued that the vocational training that the Amish provided to their children was better suited for them than regular school in a secular world, as it would prepare them for life in the Amish community. Having Amish children attend school for two more years would not harm their physical and mental well-being or make them a burden to their society. Therefore, the state's interest in universal education does not outweigh the rights protected in the First Amendment under the Exercising Freedom Clause.

Although the ruling was unanimous, Justice Willaim Douglas dissented from a part of the ruling, stating that the court should consider what the children wanted. For Justice Douglas However, the majority of the court believed that his opinion was questionable and had nothing to do with the current case.

Wisconsin v Yoder Significance

Wisconsin v. Yoder is a significant case for a few reasons. The Supreme Court's decision to side with Yoder reaffirmed a trend that had started in the 1963 case of Sherbert v. Verner where the court sided with Adell Sherbert against the state of South Carolina in a case regarding religious freedoms. the trend was one that went against the belief action doctrine which was established in the case of Reynolds v. United States in 1879.

When the Supreme Court hears a case about religious freedoms there are many factors that have to be taken into account as siding with religious freedom in every case would, as Chief Justice Morrison Waite argued in Reynolds v. United States

This argument established the Belief Action Doctrine which allowed courts to strike down cases where religious freedoms posed too great a threat or overrode established laws considered to be more important to the health of the state than the religious freedom being argued for.

In the above example, it is easy to see why a claim of "religious rights" can be abused or set a trend that is dangerous to the health and welfare of the state and established customs. The case that established this doctrine was Reynolds v. United States, a case involving the practice of polygamy. Wisconsin v. Yoder and Sherbert v. Verner saw the shift away from this doctrine as in both instances the Supreme Court could have argued a decision opposite of what it made by citing this doctrine, though the argument would have been stronger in the case of Sherbert v. Verner than Wisconsin v. Yoder.

Wisconsin v Yoder Impact

Aside from the above-stated impacts of Wisconsin v. Yoder, the case has continued to impact education in the United States. After the Supreme Court ruled in favor of Yoder, advocates for homeschooling began using the case as legal justification for their decision to withhold their children from traditional education offered by the state or private institutions.