Legacy

Plyler v. Doe: Securing Undocumented Immigrants the Constitutional Right to Education



Legacy


Since 1982, millions of undocumented students under the protection of the Plyler ruling have been granted the constitutional right to a free and accessible education. In doing so, the lives and futures of each child have been profoundly changed. 

English Language Learners lining up for lunch at the elementary school of the Tyler Independent School District, (Tyler ISD)

Hispanic children learning the English alphabet, (MALDEF)

"The case created a new generation of immigrants who know America from the inside, who speak English, and who want the same shot at the American dream that their classmates have. The case set in motion the movement that we see today, young, undocumented, immigrants pushing for the right to live and work in the United States and to go to college."
- Stephen Smith, producer of  "Shadow Class: College Dreamers in Trump's America"

DACA


Plyler v. Doe has laid the foundation for the Deferred Action for Childhood Arrivals (DACA) program. From June 2012 to July 2021, DACA has protected over 900,000 undocumented immigrants who arrived as children from deportation and provided them with work permits, allowing many to pursue higher education and build careers. ​​​​​​​

"For hundreds of thousands of immigrant youth whose home is here, DACA opened the door to opportunities and the stability many of us take for granted."
-Marielena Hincapié, Executive Director of the National Immigration Law Center

DACA supporters rally during the U.S Supreme Court hearing of the program's arguments, (NPR)

Ongoing Challenges



In the decades since Plyler v. Doe, federal legislatures and school districts have repeatedly attempted, and failed, to pass policies that undermine the ruling. The Trump Administration's Project 2025 Policy Playbook outlines initiatives to collect students’ immigration data and encourages legislation requiring proof of documentation to attend school. As of May 2025, at least three states have continued working to pass legislation limiting undocumented students' access to education. ​​​​​​​

"[New Jersey, Oklahoma, and Texas] are currently proposing actions to limit undocumented students’ access to a free, public education. Recent efforts in two other states have been paused or failed..."

- Ileana Najarro & Daniela Franco Brown, (Education Week)

For those who seek to ensure undocumented children’s access to education, the Plyler ruling has served as an indispensable safeguard against exclusionary policies. ​​​​​​​

"I have no doubt that but for that ruling, public school systems all over the country would be checking papers and tossing away their undocumented students like so much playground litter."
-Linda Greenhouse, legal journalist, (New York Times​​​)


As the Justices and judges involved in the case continuously reaffirmed, education is the cornerstone of a thriving society and there would be catastrophic consequences if any specific group was denied the ability to learn the essential skills provided by a free and full public education.

"Those who would today assert that depriving children of an education is appropriate policy should be mindful of the views of all nine Justices in Plyler."
- Thomas Saenz, current head of MALDEF