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Many schools were opened using native tongue instruction such as German, French, Dutch, Swedish, Norwegian, Spanish, Polish, Italian, Danish.. ect

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A law was passed by the Americanization Department of United States Bureau of Education determining that all education whether public or private was to be in English only. By 1923, 34 stated had decreed that English must be the sole language for primary education.

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The Bilingual Education Act indicated that bilingal education programs were to be seen as part of the federal education policy. It authorized the use of federal funds for education of non-English speakers.

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A court was brought against the San Francisco School District in 1970 due to lack of language support for Chinese speaking students. In result, the US Supreme Court outlawed submersion programs in 1974 for students who were not yet proficient in English.

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Following the ruling, the office of Civil RIghts issued a set of guidelines for school districts called the Lau Remedies.These guidelines open the doors for what we see today as English as a Second Languages classes and English tutoring in English classes.