The 1923 landmark case of Meyer v. Nebraska applied the 14th Amendment’s Due Process Clause to a law passed in Nebraska that prohibited foreign-language instruction in any school up to eighth grade. In a 7-2 decision, the Court struck down the legislation as an unconstitutional violation of individual liberties under a substantive due process analysis. Some commentators, such as Justice Kennedy, have noted that if this case was heard today it would likely be decided on 1st Amendment grounds instead.