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Cochran v. Louisiana State Board of Education

281 U.S. 370 (1930)

Facts of the Case:

Louisiana passed a statute that allowed for the purchasing of secular textbooks for all school children (secular and religious). The statute was challenged for violating the Fourteenth Amendment because the government was depriving taxpayers of their property without due process. This claim was made because the public funds were being used to benefit private organizations.


The Court upheld the Louisiana statute that provided state funds for the purchasing of textbooks for both religious and public school students.

Majority Opinion: (Justice Hughes)

The intent of the statute is to benefit the school children rather than the private schools. The state indirectly benefits from this because it will have a more educated citizenry. "The schools, however, are not the beneficiaries of these appropriations. They obtain nothing from them, nor are they relieved of a single obligation, because of them. The school children and the state alone are the beneficiaries." The statute ensures that all students have the same quality textbooks.


The Court uses a very literal interpretation to determine the beneficiaries of the statute. Even though the religious schools are spared the expenses of purchasing textbooks for their students, the Court determined that it was the individual students who received the benefit.

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