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The Naturalization Act took place in 1906. This act required immigrants to learn English to become a citizen. This is due to the idea that immigrants' lack of proficiency in the English language and English literacy was a social, political and economic concern for Americans.

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Due to the Naturalization Act, many immigrants suffered from discrimination due to their limited proficiency in the English language. As a result, when German immigrants arrived in the United States after World War I, they were not only despised because of the stigma attached to their nationality as a result of the war but also because they were not proficient in English.

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Since the happening of World War I, the German language became portrayed as a threat. This caused linguistic intolerance to peak and appear throughout America.

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After World War I, many wanted immigrants and other non-English speaking individuals to become fluent in English as soon as possible. There was widespread hostility and fear toward them; fear of the unknown. This led to the ultimate decision of English-only education.

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34 States agree with the Department of the U.S Bureau of Education's recommendation of English-only education. This led way to a more monolingual type of education.

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The state of Nebraska adopted the Department of the U.S. Bureau of Education's recommendation for English-only instruction. After World War I, there was a particularly large influx of German immigrants in the U.S. This newly implemented English-only education led to the Meyer v. Nebraska case.

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Nebraska passed a law prohibiting teaching grade school children any language other than English. Robert Meyer, who taught German in a Lutheran school, was convicted for breaking this law. In the conclusion of this case, the Supreme Court declared the law to be unconstitutional under the 14th Amendment, ruling in favor of Meyer. This is an important case because it makes clear that the 14th Amendment provides protection for language minorities.

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In both the Meyer v. Nebraska case and the Brown v. Board of Education case, the Supreme Court ruled that the issues were unconstitutional under the 14th Amendment, which addresses many aspects of citizenship and the rights of citizens.

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This landmark case that started the de-segregation movement, started with Linda Brown, a child denied entrance to a Topeka, Kansas all-white elementary school. Her father, Oliver Brown, filed a class-action suit against the Board of Education of Topeka, Kansas. The argument was, "separate but equal doesn't mean equal".  The Supreme Court ruled unanimously that racial segregation of children in public schools was unconstitutional, leading to desegregation in public schools. By ruling that states are responsible for providing "equal educational opportunities" for all students, Brown made bilingual education for ELLs more feasible.

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Bilingual education became more legitimate and constitutional as a result of Brown v. Board of Education. The Court determined that the intentional segregation of minority students—including those who speak different languages—violates the equal protection clause. Because of the greater emphasis it placed on equality and bilingual education, this case contributed to the passage of legislation like the National Defense Act.

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The U.S. felt that they were falling behind in certain technological fields when the Russians launched the orbiting satellite, Sputnik into space. Due to this, the National Defense Education Act provided aid to both public and private schools at all levels to advance the areas of science, math, and modern foreign languages. The act also provided aid to English as a Second Language programs.

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Bilingual education programs received sufficient funding and support in both the National Defense Act and Coral Way Elementary to develop or improve the programs. However, funding for Coral Way came from the public, whereas funding from the National Defense Act came from the government.

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After the Cuban revolution of 1959, Miami, Florida saw an influx of Spanish-speaking immigrants and refugees. Operation Pedro Pan was an early 1960s program that allowed Cuban parents to send their children to the U.S. This resulted in more than 14,000 children being sent to Miami. Florida-educated, middle-class Cubans then set up a bilingual school, Coral Way Elementary.  Although some schools had offered similar programs for those who spoke languages such as German and Italian, Coral Way became known as the nation's first public school with a bilingual and bicultural education program for both English and Spanish speakers.

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In the Civil Rights Act, school districts that receive federal aid are required to ensure that minority students are getting the same access to programs as non-minorities. Among these minority groups are language minority students. Similar to this sentiment, in the case of Coral Way Elementary, funds were given to ensure that language minority students were given access to equal educational opportunities.

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This act prohibited discrimination on the account of color, race, religion, sex, and national origin. It strengthened the enforcement of voting rights and desegregation of schools. Provisions of this act also prohibited discrimination on the account of sex. Although this does not address bilingual education directly, it opened an important door. School districts that receive federal aid are required to ensure that minority students are getting the same access to programs as non-minorities since they are prohibited from discriminating. This minority group includes language minority students.

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The Civil Rights Act essentially paved the way for bilingual education programs. It prohibited discrimination against certain groups, including non-English speakers. This allowed for more widespread acceptance of bilingualism and bilingual education, leading to the Elementary and Secondary Education Act. Individuals like President Lyndon B. Johnson began to realize the importance of these programs.

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The Elementary and Secondary Education Act (ESEA) was passed by U.S President Lyndon B. Johnson. It provided funds to programs considered essential for children in public schools. This included Bilingual Education programs.

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After bilingual education programs were considered essential by President Lyndon B. Johnson in the ESEA Act, the Bilingual Education Act was passed, requiring all schools to provide BLE programs.

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This act required schools to provide bilingual education programs. The law was passed at a time of increased immigration and a vibrant civil rights movement. Included in this act is the allocation of federal funding to encourage local school districts to try methods of incorporating instruction in students' mother tongue. This is the first time that the US Congress has approved funding for bilingual education. Most states have followed the direction of the federal government, enacting their own bilingual education laws or at least eliminating the use of another language in the classroom. In its first year, the law funded 76 bilingual education programs and served students of over 14 different languages.

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Although bilingual education programs were now mandated due to the Bilingual Education Act, some states did not follow the direction of the federal government, maintaining English-only instruction. San Francisco was one of them, which resulted in the Lau v. Nichols case.

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This case was another landmark for bilingual education. Chinese students who transferred from their mother country, were placed into classes and forced to repeat and fail due to being taught in only English, a language that they didn't understand. English language courses were provided to less than a third of the students, since the San Francisco Unified School District administration believed it wasn't their job to provide English classes. In this case, the students alleged that they were not provided with equal educational opportunities and, therefore, were not being afforded their Fourteenth Amendment rights. The Supreme Court agreed, stating that simply providing the same facilities, books, teachers, and curriculum to these students was not equal treatment.

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In both the Lau v. Nichols case and the Castañeda v. Pickard case, there were allegations of discriminatory behavior and unequal educational opportunities. In both outcomes, the Supreme Court agreed, requiring that adequate resources and personnel must be a part of bilingual education.

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This case occurred in Raymondville, Texas Independent School District in 1981. Mexican American children and their parents claimed that the district was discriminating against them because of their ethnicity. They argued that classrooms were segregated using a grouping system based on racially and ethnically discriminatory criteria. The Supreme Court ruled in favor of the Raymondville Independent School District, stating they had not violated any of the Castañeda children's constitutional or statutory rights. Despite this ruling, Castañeda v. Pickard established three requirements for bilingual education through a decision by the 5th Circuit Court:

-It must be based on a sound educational theory.

-It must have an effective implementation with adequate resources and personnel.

-After a trial period, it must be evaluated as effective in overcoming language handicaps.

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In the Castañeda v. Pickard case, Castañeda claimed that the Raymondville Independent School District failed to establish sufficient bilingual education programs, which would have aided his children in overcoming the language barriers that prevented them from participating equally in the classroom. Like the RISD, proposition 227 restricted BLE programs and bilingualism.

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This proposition mandated that English learners entering California schools be placed in structured English immersion programs for a period not normally exceeding one year, then be transferred to mainstream classrooms taught in English. It severely restricted bilingualism and limited bilingual education.

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In both Proposition 227 and the No Child Left Behind Act, severe restrictions were placed on bilingual education, forcing English-only instruction to become the norm (inexplicitly in NCLB). Both instances brought a deficit view of emergent bilinguals.

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A U.S. law enacted in 2001 that was intended to increase accountability in education by requiring states to qualify for federal educational funding by administering standardized tests to measure school achievement. Bilingual education programs were still allowed but left to the determination of the states. English-only instruction was strongly encouraged. This act brought back a deficit, subtractive view of emergent bilinguals, labeling them as Limited English Proficient (LEP).

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The Race to the Top (RTTT) program and the No Child Left Behind (NCLB) Act deal with many of the same issues and have many of the same goals, but their approaches are different. One provides incentives for schools to change (RTTT), the other mandates it (NCLB). States and local school districts that receive RTTT grants will receive additional federal funding. The NCLB requires states to make reforms in order to continue receiving federal funds they are already getting. But the two programs address many of the same issues: standards and assessments, data and accountability, effective teachers and principals, and ways of turning around low-performing schools.

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Race to the Top was a competitive fund of 4.3 billion dollars made by Obama to promote school improvement on the state and local level. State governments were called upon to submit their plans for school reform. School reform involved 4 key areas: (1) adoption of a better data system of student progress to the teachers and parents; (2) more effective support for teachers and school leaders; (3) resources provided for the rigorous interventions required to turn around the lowest performing schools and a development of higher standards and better assessments. In this case, it affected teachers by making their evaluations based off of their students test scores.

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Federal officials used the incentive of Race to the Top funding during a significant economic recession to direct states toward paths aligned with the Obama Administration’s vision for education reform, including state adoption of the Common Core. On the Race to the Top grant application, states that promise to implement the Common Core (or an equivalent) could receive up to 70 points out of a possible 500.

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Common Core, or the Common Core State Standards Initiative, is an educational initiative that outlines benchmarks in English-language arts and mathematics at each grade level from kindergarten through high school. This requires all students in that state to test at the same level.

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All states requesting ESEA flexibility must prove to the Department of Education that they have expectations for college and career readiness for all students, including ELLs. The department's requirements for what constituted standards for college and career preparedness were likely to be met by the Common Core State Standards.

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Elementary and Secondary Education Act Flexibility 

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This initiative takes the Elementary and Secondary Education Act and the No Child Left Behind Act and allows flexibility. This ensures no one will suffer when the curriculum narrows and educators devote precious classroom time by teaching to the test. Under ESEA Flexibility, states will begin to move beyond the standardized tests that are based on arbitrary proficiency levels. By measuring student growth and critical thinking, new assessments will inspire better teaching and greater student engagement across a well-rounded curriculum.

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In both ESEA Flexibility and the Every Student Succeeds Act, the government was seeking to improve NCLB by addressing standardized testing.

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This act was meant to bring the No Child Left Behind Act to an end, seeking to address problems like grant distribution and requirements, testing and accountability standards, budgetary accountability requirements, and teacher evaluation. It focuses on lessening federal control over education and boosting state control over how funds are used. It includes funding for developing programs for American Indian and Alaska Native kids, upgrading underperforming schools, and offering language instruction educational programs—all of which are particularly relevant to bilingual education.

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Baker, C., & Wright, W. E. (2021). Foundations of Bilingual Education and Bilingualism (7th ed., Ser. 127). Multilingual Matters.

Everett-Haynes, L. M. (2008, January 15). How Coral Way,       Florida Made History in Two Languages. University of Arizona News. https://news.arizona.edu/story/how-coral-way-florida-made-history-two-languages.

Lee, A. (2020, October 22). Common Core State Standards. Understood. https://www.understood.org/en/articles/common-core-state-standards-what-you-need-to-know.

Lohman, J. (2010, June 4). Comparing No Child Left Behind and Race to the Top.  OLR Research Report. https://www.cga.ct.gov/2010/rpt/2010-r-0235.htm.

Spring, J. (2022). American Education (20th ed.). Routledge.

Wright, W. E. (2018, January 29). Landmark Court Rulings Regarding English Language Learners. Colorín Colorado. https://www.colorincolorado.org/article/landmark-court-rulings-regarding-english-language-learners.