Minersville School District v. Gobitis facts for kids
Quick facts for kids Minersville School District v. Gobitis |
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| Argued April 25, 1940 Decided June 3, 1940 |
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| Full case name | Minersville School District, Board of Education of Minersville School District, et al. v. Walter Gobitis, et al. |
| Citations | 310 U.S. 586 (more)
60 S. Ct. 1010; 84 L. Ed. 1375; 1940 U.S. LEXIS 1136; 17 Ohio Op. 417; 127 A.L.R. 1493
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| Prior history | Judgment for plaintiffs, injunction granted, 24 F. Supp. 271 (E.D. Pa. 1938); affirmed, 108 F.2d 683 (3d Cir. 1939); cert. granted, 309 U.S. 645 (1940). |
| Subsequent history | None |
| Holding | |
| The First Amendment does not require States to excuse public school students from saluting the American flag and reciting the Pledge of Allegiance on religious grounds. Third Circuit reversed. | |
| Court membership | |
| Case opinions | |
| Majority | Frankfurter, joined by Hughes, McReynolds, Roberts, Black, Reed, Douglas, Murphy |
| Dissent | Stone |
| Laws applied | |
| U.S. Const. amends. I, XIV | |
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Overruled by
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| West Virginia State Board of Education v. Barnette, 319 U.S. 624 (1943) | |
Minersville School District v. Gobitis was a major decision by the Supreme Court of the United States in 1940. It was about the religious rights of students in public schools. The case focused on whether schools could make students salute the American flag and say the Pledge of Allegiance.
The Court decided that public schools could require students to do this, even if it went against their religious beliefs. This specific case involved students who were Jehovah's Witnesses. This ruling caused more difficulties for Jehovah's Witnesses in the United States. However, the Supreme Court changed its mind and overturned this decision just three years later in a case called West Virginia State Board of Education v. Barnette (1943).
Contents
Why Did This Case Happen?
Flag Pledges and Patriotism
During times of war, like the Spanish–American War and World War I, many schools in the United States started requiring students to say the Pledge of Allegiance. This was done to encourage patriotism and national unity. Most people followed these rules, but some groups had concerns.
Jehovah's Witnesses and Their Beliefs
In 1935, the leader of the Jehovah's Witnesses, J. F. Rutherford, spoke about flag saluting. He explained that saluting an earthly symbol and believing it could bring salvation was not faithful to God. While it wasn't an official rule at first, many Witness families soon decided not to salute the flag.
A third-grade Jehovah's Witness student named Carleton Nichols was expelled from school in Massachusetts for refusing to say the Pledge. This event received a lot of attention. Other Witness students began to do the same. Soon, schools across the country started expelling Witness students and even firing Witness teachers. The Jehovah's Witnesses then made it an official part of their faith. They even set up their own "Kingdom schools" for their children.
The Gobitas Family's Story
Walter Gobitas, a new Jehovah's Witness, was inspired by other Witnesses who stood up for their beliefs. He told his children, Lillian and Billy, not to say the Pledge of Allegiance at their school in Minersville, Pennsylvania.
Minersville was mostly Roman Catholic, and there was already tension with Jehovah's Witnesses. Lillian and Billy faced teasing and attacks from other students. Lillian lost her friends and her role as class president. Billy's teacher even tried to force his arm out of his pocket to make him salute.
The Gobitas family also faced economic hardship. A local church organized a boycott of their family store, and their business suffered. After being expelled from school, their father had to pay for them to attend a private school. The school board eventually got permission to expel the Gobitas children without appeal.
The Court Cases
The First Trial
The case went to trial in Philadelphia in February 1938. The school superintendent, Roudabush, believed the children were "indoctrinated." He thought that even a few students refusing the pledge would "demoralize" others and lead to a lack of respect for the flag and American values.
However, four months later, District Judge Albert B. Maris disagreed. He ruled that making the children salute the flag was unconstitutional. He said it violated their right to freely practice their religious beliefs.
The Appeal
The school board quickly decided to appeal this decision. The appeal was heard by the Third Circuit of the U.S. Court of Appeals in November 1938. A year later, all three judges on the court agreed with the district court's decision.
Despite losing twice, the school board decided to take their case to the highest court: the Supreme Court. The Supreme Court agreed to hear the case in March 1940.
Arguing Before the Supreme Court
The Supreme Court heard arguments on April 25, 1940. Joseph Rutherford, the president of the Watch Tower Society and a lawyer himself, led the defense. He was helped by Hayden C. Covington, who was the new head of the religious group's Legal Department. Other organizations, like the American Civil Liberties Union, also submitted their opinions to the Court.
The Supreme Court's Decision
The Supreme Court's decision was almost unanimous, with an 8-to-1 vote. The Court decided to uphold the mandatory flag salute. This meant they agreed that schools could require students to salute the flag.
Justice Felix Frankfurter wrote the main decision for the majority. He focused on the idea of "secular regulation." This means balancing a government rule that has a non-religious purpose against how it affects religious practices. He saw the Pennsylvania flag-salute rule as a non-religious policy meant to encourage patriotism in students.
Frankfurter explained that the school district's goal of creating national unity was important enough to require students to salute the flag. He believed that the nation needed loyalty and unity from all its people. Since saluting the flag was a key way to achieve this, it was a matter of national importance.
The Court stated that the state's interest in "national cohesion" (meaning national unity) was "inferior to none in the hierarchy of legal values."
He wrote:
National unity is the basis of national security. To deny the legislature the right to select appropriate means for its attainment presents a totally different order of problem from that of the propriety of subordinating the possible ugliness of littered streets to the free expression opinion through handbills.
Frankfurter argued that the need for people to follow this rule was more important than the individual religious freedom claims of the Jehovah's Witnesses. He stressed that:
Conscientious scruples have not, in the course of the long struggle for religious toleration, relieved the individual from obedience to a general law not aimed at the promotion or restriction of religious beliefs
He also wrote that saying the Pledge helped promote patriotism in the United States. He believed that the country's foundation as a free society depended on building strong emotional ties to the nation.
The Court found that the flag was a vital symbol of national unity. It could be used in laws designed "to promote in the minds of children who attend the common schools an attachment to the institutions of their country."
The Dissenting Opinion
Justice Harlan F. Stone was the only judge who disagreed with the majority decision. He wrote:
The guarantees of civil liberty are but guarantees of freedom of the human mind and spirit and of reasonable freedom and opportunity to express them ... The very essence of the liberty which they guarantee is the freedom of the individual from compulsion as to what he shall think and what he shall say ...
He believed that forcing someone to say or think something went against the very idea of freedom.
What Happened After the Decision?
The Gobitis decision led to a difficult time for Jehovah's Witnesses.
- On June 9, a large group of people burned down a Kingdom Hall (a place of worship for Jehovah's Witnesses) in Kennebunkport, Maine.
- On June 16, police in Litchfield, Illinois, jailed all sixty Witnesses in the town, supposedly to protect them from their neighbors.
- On June 18, people in Rawlins, Wyoming, attacked five Witnesses.
- On June 22, people in Parco, Wyoming, tarred and feathered another Witness.
The American Civil Liberties Union reported that nearly 1,500 Witnesses were physically attacked in over 300 communities across the country. One sheriff in the South reportedly told a reporter why Witnesses were being forced out of town: "They're traitors; the Supreme Court says so. Ain't you heard?"
First Lady Eleanor Roosevelt publicly asked for calm. Many newspaper editorials and legal experts criticized the Gobitis decision, saying it was a blow to freedom. On June 8, 1942, Supreme Court Justices Black, Douglas, and Murphy stated that they now believed the Gobitis case had been decided incorrectly, even though they had agreed with the majority at the time.
The Decision Is Overturned
Because of the violent reactions to the Gobitis decision, the ruling did not last long. Justice Frank Murphy especially regretted his vote and wanted to revisit the issue. Also, Justice Harlan Fiske Stone became the Chief Justice, and two new judges joined the Supreme Court. These changes helped lead to a new decision.
On June 14, 1943 (Flag Day), the Supreme Court issued a new ruling in the case of West Virginia State Board of Education v. Barnette. In this case, Justices Murphy, Black, and Douglas changed their minds, leading to a 6–3 vote that overturned the Gobitis decision.
Justice Robert Jackson wrote the majority opinion for the Barnette case. He echoed Justice Stone's earlier dissent, writing: "If there is any fixed star in our constitutional constellation, it is that no official, high or petty, can prescribe what shall be orthodox in politics, nationalism, religion or other matters of opinion." This powerful statement meant that no government official could force people to believe or say certain things about politics, national identity, or religion.
After this new ruling, the attacks on Jehovah's Witnesses decreased. However, thousands were still arrested during World War II for seeking religious exemption from military service. They were sometimes accused of being unpatriotic or even Nazi sympathizers.
