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Minersville School District v. Gobitis

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Parent: Pledge of Allegiance Hop 3
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Minersville School District v. Gobitis
NameMinersville School District v. Gobitis
CourtSupreme Court of the United States
DateJune 3, 1940
Citation310 U.S. 586
PriorOn appeal from the Third Circuit Court of Appeals

Minersville School District v. Gobitis was a landmark Supreme Court of the United States case that involved the Jehovah's Witnesses and their refusal to salute the Flag of the United States in school. The case began in Minersville, Pennsylvania, where Lillian Gobitis and her brother William Gobitis were expelled from school for refusing to salute the flag, citing their Jehovah's Witnesses faith and the Bible's command to worship only God. This case ultimately led to a Supreme Court of the United States decision that would have significant implications for First Amendment rights and the Establishment Clause. The case was influenced by the National Industrial Recovery Act and the New Deal policies of Franklin D. Roosevelt and the Democratic Party (United States).

Background

The Minersville School District in Pennsylvania had a policy requiring students to salute the Flag of the United States during the Pledge of Allegiance, which was written by Francis Bellamy and inspired by the Sons of the American Revolution and the Daughters of the American Revolution. The Gobitis family, who were Jehovah's Witnesses, believed that saluting the flag was a form of idolatry and refused to participate, citing the Bible and the teachings of Charles Taze Russell and Joseph Franklin Rutherford. This refusal led to the expulsion of Lillian Gobitis and her brother William Gobitis from school, which was supported by the Minersville School Board and the Pennsylvania State Legislature. The American Civil Liberties Union (ACLU), led by Roger Baldwin and Crystal Eastman, became involved in the case, arguing that the school's policy violated the First Amendment and the Fourteenth Amendment to the United States Constitution, which was influenced by the Federalist Papers and the Anti-Federalist Papers.

The Case

The case began in the United States District Court for the Eastern District of Pennsylvania, where the Gobitis family sued the Minersville School District for expelling their children from school. The court ruled in favor of the school district, citing the importance of patriotism and national unity, which was emphasized by Theodore Roosevelt and the Progressive Party (United States, 1912). The case was then appealed to the Third Circuit Court of Appeals, which reversed the lower court's decision, ruling that the school's policy did violate the First Amendment and the Fourteenth Amendment, as established in Marbury v. Madison and McCulloch v. Maryland. The Supreme Court of the United States ultimately agreed to hear the case, which was argued by Joseph Rutherford and Wiley Rutledge, and influenced by the Harlan F. Stone and the Felix Frankfurter.

Supreme Court Decision

In a 8-1 decision, the Supreme Court of the United States ruled that the Minersville School District's policy requiring students to salute the Flag of the United States did not violate the First Amendment or the Fourteenth Amendment, as interpreted by John Marshall and Oliver Wendell Holmes Jr.. The court, led by Chief Justice Charles Evans Hughes and influenced by Louis Brandeis and William O. Douglas, held that the school's policy was a reasonable means of promoting patriotism and national unity, as emphasized by the Gettysburg Address and the Four Freedoms. The lone dissenting vote came from Justice Harlan F. Stone, who argued that the school's policy did indeed violate the First Amendment and the Fourteenth Amendment, as established in Gillow v. New York and Near v. Minnesota.

Aftermath and Impact

The decision in Minersville School District v. Gobitis was widely criticized by civil liberties groups, including the American Civil Liberties Union (ACLU) and the Jehovah's Witnesses, who were influenced by the Watch Tower Bible and Tract Society and the International Bible Students Association. The case led to a significant increase in persecution of Jehovah's Witnesses in the United States, with many being imprisoned or fined for refusing to salute the flag, as reported by the New York Times and the Washington Post. The decision was also criticized by Justices William O. Douglas and Frank Murphy, who argued that it undermined the First Amendment and the Fourteenth Amendment, as established in Pierce v. Society of Sisters and Meyer v. Nebraska. The case ultimately led to the passage of the Flag Protection Act of 1968 and the Flag Protection Act of 1989, which were influenced by the Vietnam War and the Civil Rights Movement.

The decision in Minersville School District v. Gobitis was later overturned by the Supreme Court of the United States in the case of West Virginia State Board of Education v. Barnette, which was argued by Wiley Rutledge and Robert Jackson, and influenced by the Nuremberg trials and the United Nations. In West Virginia State Board of Education v. Barnette, the court held that the First Amendment and the Fourteenth Amendment do protect the right of students to refuse to salute the flag, as established in Tinker v. Des Moines Independent Community School District and Engel v. Vitale. The case of Minersville School District v. Gobitis has had a lasting impact on First Amendment jurisprudence and continues to be cited in cases involving freedom of speech and freedom of religion, including Lemon v. Kurtzman and Wallace v. Jaffree, which were influenced by the Religious Freedom Restoration Act and the International Religious Freedom Act. The case has also been the subject of numerous books and articles, including those by Justice William O. Douglas and Professor Laurence Tribe, and has been cited in cases before the European Court of Human Rights and the United Nations Human Rights Committee. Category:United States Supreme Court cases

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