Prince v. Massachusetts

Summary

The Supreme Court considered whether Massachusetts child labor laws, as applied to a child distributing Jehovah's Witness literature on public streets, violated the custodian's and child's rights to religious freedom, parental authority, and equal protection. The Court held that the state's authority to protect children's welfare permits greater regulation of children's public activities than comparable adult activities and affirmed the convictions. Justice Murphy dissented.

Holdings

1. A state may apply child-labor laws to prohibit children from distributing or offering religious literature for sale on public streets, even when the activity is undertaken pursuant to religious belief and with a parent or guardian present.
2. Applying the child-labor prohibition to Jehovah's Witness children did not deny equal protection because the law excluded those children from conduct prohibited to all children alike.
3. Parental or custodial authority to direct a child's religious training does not prevent the state from regulating the child's labor and public conduct to protect the child's welfare.

Questions Presented

1. Whether Massachusetts General Laws chapter 149, sections 80 and 81, as applied to a child distributing or offering religious literature on public streets, violated the First Amendment's protection of religious freedom as applied to the states through the Fourteenth Amendment.
2. Whether the statutes violated Prince's parental or custodial liberty under the Fourteenth Amendment's Due Process Clause.
3. Whether applying the statutes to Jehovah's Witness children denied equal protection of the laws.

Disposition

affirmed