Running head: BREAKING THE LANGUAGE BARRIER 1

Breaking the Language Barrier: ESL Education within the Public School Systems

Josephine M. Barrios Cristales

First Colonial High School

Legal Studies Academy

BREAKING THE LANGUAGE BARRIER 2

Abstract

This paper examines the English as a Second Language Education (ESL) within the public

school systems in the United States. The author examines legislation concerning the education of

English language learners, as well as how it continues to impact students today. The author

analyzes how the current practices concerning the instruction of students, with limited English

proficiency, fails to successfully break the language barrier, which in turn causes various

ramification. This paper also includes the different methods on ESL education and a comparison

between English-only and bilingual instruction.The author includes a personal story of an ESL

student within the United States public education system and its specific faults. Lastly, this paper

will address the specific impacts on students and offer methods to improve said system.
BREAKING THE LANGUAGE BARRIER 3

Breaking the Language Barrier: ESL Education within the Public School Systems

“Every student can learn, just not on the same day or in the same way” (G. Evans).

Imagine sitting in a classroom, forced to stare blankly at the teacher. You have absolutely no idea

what is going on around you and are unable to ask a single question. You are expected to retain

information that is presented to you in a completely foreign language. You know nothing about

the language or the culture that immerses your environment. Those around you are constantly

judging you and resort to labels such as “uneducated” because you do not possess the ability to

comprehend. The feeling of frustration and utter loneliness settles in. This is the hardship almost

4 million children are forced to face everyday (NCES, 2015). English Language Learners are

thrown into foreign environments without the ability to communicate with those who surround

them. Public school systems have an obligation to provide equal access to education for every

single student, but fall short in regards to those student in need of ESL instruction. English as a

second language, or ESL education, is intended to improve the English proficiency of ELL’s,

those individuals whose first language is not English. The lack of policies and laws regulating

these programs as well as the inability to include crucial methods of instruction is responsible for

the ineffectiveness of this system. Current English as a Second Language education within the

public school systems in the United States obstructs English Language Learners (ELLs ) ability

to reach proficiency in the English language which in turn, impedes their ability to prosper in

their academic endeavors as well as thrive beyond.

History of ESL Education

They desperate need for ESL education was intensified by the flood of immigrants the

United States experienced during the 17th and 18th centuries. Although the different cultures and

languages were initially welcomed, individual’s mindsets began to change towards to the end of
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the 1900’s. People were no longer accepting of the differing languages or cultures of immigrants,

so schools started the implementation of English-only classrooms and environments. These

environment and policies made it almost impossible for students within the public school

systems to comprehend material taught to them. Disregarding the need for ESL education

continued up until the 1960’s when government intervention began (Hamel, 2017).This was a

direct result of the end of the Cuban revolution in 1959 (FindLaw, 2017). The arrival of

countless immigrants from Cuba to Dades County, Florida, demanded ESL instruction which

soon spread throughout the United States. A program known as “Spanish for Spanish Speakers”

was initiated which consisted of bilingual instruction by U.S. and Cuban educators. Coral Way

Elementary was the first to implement said program in the first through third grade classrooms.

The bilingual education system started by Dades County provided their students which

instruction in both english as well as spanish. This resulted in students being both bilingual and

bicultural (MDC Public Schools, 2017). The commencement of Cuban nationals seeking asylum

within the United States was the impetus for the model Dades County set (Hamel, 2017).

Court Cases and Legislation

The Civil Rights Act of 1964

The Civil Rights Act of 1964 laid a foundation for legislation which would govern ESL

education in the years to come. This act was signed into law by President Johnson and protects

individuals from being discriminated against because of their race. Title VI of the act addresses

discrimination within the public school systems and requires schools which receive federal

funds, provide equal access to education for all students (FindLaw, 2017). This means that

schools must pay particular attention to guaranteeing that the minority populations are provided

with the proper resources. These resources must guarantee the minority group of students have
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the same chance to achieve academically as the majority does. Not only do these requirements

apply to racial minorities, but language minorities as well. Students are identified as being in the

language minority if the individual lives in a house where the language spoken is not English.

These standards served as an introduction for future legislation concerning the rights of ESL

students (Wright, 2012).

The Elementary and Secondary Education Act (Bilingual Education Act)

Title VII of the Elementary and Secondary Bilingual Education Act was approved by

president Lyndon Johnson and enacted in January of 1968. Also known as the Bilingual

Education Act, it is recognized as the first piece of legislation to specifically address the

respective rights of children with limited English abilities and specify the need of ESL education.

This piece of legislation requires schools use monetary resources granted by the government to

initiate bilingual education or instruction for students with limited English proficiency. In

accordance with the particular introduction of bilingual instruction by this act, the intention was

to establish joint curriculums similar to that seen in Dades County, Florida. As a part of this

particular type of curriculum, students with limited English abilities would be placed in

classrooms with Spanish instruction until they reached the capacity to join their fellow peers in

English speaking classrooms. This act had been amended in the years following its initial

enactment. The amendments from the years 1974, 1978, 1984, 1988, and 1994, were intended to

clarify prior verbatim used in the original piece of legislation, broadening the methods of

instruction for ESL students, and increase federally funding for the listed programs. Also, the

amendment made in 1978 was made to define and extend the parameter for students who qualify

for ESL instruction. This means that students who are English speaking as well as have limited

English proficiency, may be permitted in programs such as bilingual education. A huge

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milestone was hit with the amendment in 1984, which significantly increased the authority

school systems had to provide whatever form of instruction they saw fit for the English language

learners in their respective school district (FindLaw, 2017).

Department of Health, Education, & Welfare Memorandum 1970

In May of 1970, a memorandum pertaining to the education of English language learners

as well as their rights was issued. The purpose of of the memorandum was to clarify the

regulations established by the Civil Rights Act of 1964 and how they specifically pertain to

students in the public education system with limited English language abilities. Because of the

language barrier that million of children struggle with while in school, the government required

that schools take the proper action to prevent any discrimination of these students based upon

their national-origin or background. By prohibiting and pointing out this particular type of

discrimination, as it relates to ELL’s, the memorandum put the responsibility of providing an

equal playing field to all student on the shoulders of any and all federally funded schools. The

issue which arose with the memorandum was its lack of specification in regards to the manner in

which procedures the school systems must take part in to provide ELL’s with an equal

opportunity to education. This lack of uniformity causes a tremendous amount of grey area for

establishing what students must be provided with to be able to overcome the language barrier

and progress academically(NCELA, 2006). Although the memo fails to address specific actions

schools must partake in, it does in fact state what acts violates the rights of the students. The

main violations which are mentioned include excluding children belonging to a national minority

from classes at the proper grade level classes because of their limited capacity to speak and

understand English. Violations also include inappropriately placing ELL’s in special education

classes because of their lack of English capacity. Lastly, schools are prohibited from sending an
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ELL’s notification of placement into an ESL program or any other school notification in English

to a student's parent/guardian if they are also possess limited English abilities. Schools must

provide these families with notifications in their primary language (Office for Civil Rights,

2017).

Lau v. Nichols

This case began in 1971 after the San Francisco school system was officially

integrated. After this integration, almost 3,000 students from China or Chinese families were

brought into the respective school systems. These students were unable to comprehend the

English language, and each classroom practiced English-only instruction. The school system

provided “supplementary English language” courses, but only to 1,000 students. This

supplementary English classes mimicked appropriate English as a Second Language education.

These classes were intended to lessen the language barrier and help improve the English

proficiency of the integrated students. Those students who did not receive the supplementary

classes, like Lau, filed a lawsuit against the school system claiming that their failure to provide

all these students with the ESL assistance violated the Civil Rights Act of 1964. The laws which

govern this case include the 14th Amendment, Civil Rights act of 1964, as well as Elementary

and Secondary Education Amendment of 1968 (Bilingual Education Act) . On January 21st,

1974, the U.S. Supreme Court issued a ruling in favor of Lau. This unanimous decision was

made based on Section 601 of the Civil Rights Act of 1964. The Supreme Court concluded that

because the school system operated under federal funds, these ESL resources would be mandated

so that equal opportunities and access to all student may exist. The court stated that because the

children were unable to comprehend what was going on in the classes taught in pure English, it
BREAKING THE LANGUAGE BARRIER 8

was a violation of the equal opportunities act (Wright, 2012).

ASPIRA v. Board of Education of New York

A non-profit association advocating for the Latino community known as ASPIRA filed a

class action lawsuit against the New York board of education in the Fall of 1972. On September

2nd of that year, attorneys from the Puerto Rican Legal Defense and Education Fund accused the

New York Board of Education of failing to “provide an equal education opportunity” to the

ELL’S, specifically Puerto Rican students in the respective schools. The defense claimed that

these students were being discriminated against because of the lack of programs assisting the

non-English speaking children in achieving academically within the school system. Therefore,

ASPIRA demanded the board of education institute bilingual education. Almost two years after

this case was brought before the court, the ASPIRA Consent Decree was signed and put into

action (Sanabria, 2014). On August 29th, 1974, the decree was signed by both ASPIRA and the

New York City Board of Education agreeing that the school system would implement bilingual

education for ELL’s by the start of the following school year. The decree included a clause that

ensured students who were enrolled in the ESL program promised, would be provided with

support staffs. Each school or district in the respective system has to adhere to the listed

standards if they received federal funds (ASPIRA, 2009).

Equal Educational Opportunities Act of 1974

After the precedents and regulation set by the pieces of legislation mentioned above, a

step further was taken to clarify the vagueness of the particular language used in the prior acts,

specifically what it means to provide equal education. Two years prior to the enactment of the

Equal Educational Opportunity Act (EEOA), President Nixon specified what constitutes as

providing all students with equal opportunities to the same caliber of education. Nixon publicly
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announced a proposal regarding the issues with school buses and transportation as well as what

equal educational opportunity means. This act specifically forbid intentionally discriminating

against a student (U.S. Legal, 2017). It reiterates the responsibility schools have to take proper

action or take appropriate action or the proper steps to provide an impartial environment for

these children. As it pertains to the student with limited English proficiency, even though ESL

regulations is not specifically stated in the act, the U.S. legal system has interpreted to do so.

Because of the ruling made in the case of Lau v. Nichols, the precedent had been set to interpret

appropriate action for the implementation of equal opportunities to include the bilingual

education or supplementary classes to non-english speaking students. In order for schools to act

in accordance with this piece of legislation, they must provide resources and English instruction

to ELL’s. Failing to do so would leave the language barrier intact, hindering a student's ability to

properly participate in an educational institution, therefore obstructing their right to an

educational equal to that of someone who holds proficient English capabilities (Law & Higher

Edu, 2017).

Castañeda v. Pickard (1981)

In the summer of 1978, Mr. Roy Castañeda filed a suit against the Raymondville

Independent School District (RISD). Mr. Castaneda initially alleged that RISD were unjustly

discriminating against his two Mexican-American children, Elizabeth and Katherine, and failing

to provide the proper bilingual instruction to break the language barrier mandated by law after

the decision made in the Lau v. Nichols case. Mr. Castaneda claimed that school was segregated

his children and other Mexican-American children from the rest of the student body by grouping

them all in the same classrooms. This grouping was referred to as ability grouping which means

students were placed together was said to because they shared the same weakness and talents, but
BREAKING THE LANGUAGE BARRIER 10

the school system failed to realize that separating all the Mexican-American students was view

as both racially and ethnically discriminating (Clint, 2017). Mr. Castaneda made an additional

claim that the bilingual education or instruction provided by the school his daughter attended did

not meet the standard set by precedents such as the Lau v. Nichols decision. Subsequently, RISD

was accused of violating both the Civil Rights Act of 1964 and the Equal Educational

Opportunities Act of 1974. On August 17th, 1978, the case brought upon by Castaneda was

decided in the United States District Court for the Southern District of Texas (Gucwwa, 2013).

The court ruled in favor of the Raymondville Independent School District stating that their

grouping practices did not violate the civil rights of the students and that the bilingual education

provided was sufficient in breaking the language barrier (Stanford, 2017). Castaneda then

appealed the decision made by the United States District Court for the Southern District of

Texas. In 1981, the case reached the U.S. Court of Appeals who ruled in favor of Castaneda and

reversed the decision made by the previous court. This decision had a huge lasting impact on the

education of English Language Learners of students with Limited English Proficiency. By

created a new set of guidelines or criteria. The three pronged test for determining whether or not

a program provided provided is in fact sufficient for ELL’s is as follows:

The bilingual education program must be based on sound educational theory. The

program must be implemented effectively with resources for personnel, instructional materials,

and space. After a trial period, the program must be proven effective in overcoming language

barriers/handicaps (Del Valle, 2003). These guidelines took the ensurement of proper education

for students with limited English proficiency a step further by not only stating that these students

do have a right to ESL education, but what constitutes as a sufficient program. The appeal made

in the Castaneda case was a crucial step in establishing proper regulations and requirements to
BREAKING THE LANGUAGE BARRIER 11

ensure English language learners are receiving the best possible resources to break the language

barrier (Rosenthal, 2016).

Personal Anecdotes

Esmeralda* is a sophomore enrolled in the ESL education program at her respective high

school. At the age of 12, she was forced to witness the death of two close family members. This

15 year old girl is from El Salvador, a country known for its heinous gang violence. In her final

days living in the country she once called home, various members from the infamous MS-13

invaded her family’s house and forced everyone out. They robbed her home of all her

belongings, and shot two members of her family right in front of her. Immediately, Esmeralda

and her family made the decision to leave El Salvador and seek refugee in the United States.

Once arriving to this country, she soon began the process of registering for school. She was filled

with fear as she began her first year of high school. She walked in not knowing anything and

having absolutely no ability to speak or understand English. She says her fellow classmates in

the ESL program were her biggest support and source of help. During her first year in the

program, she receive ESL services at a facility outside of her home school. Everyday, Esmeralda

and many other students endured the lengthy bus trip to and from the facility, making various

stops at schools within the districts. Esmeralda explains how much instructional time was wasted

by this transit to the separate facility. As Esmeralda began her second year, the school district

implemented a pilot program which included on-site instruction. This meant the issues associated

with the bus trips were eliminated and English language learners such as Esmeralda received

ESL instruction at their home school. Problems still arose with the new on-site program.

Esmeralda still feels as though the program falls short of truly breaking the language barrier

especially when it comes to learning content in her regular core classes. She stated how bilingual
BREAKING THE LANGUAGE BARRIER 12

instruction rather than an English-only classroom would be much more beneficial since her first

language, as well as that of her fellow classmates, is Spanish. Esmeralda also wishes the program

would become more interactive and that she could receive more personal instruction from her

teacher rather than the repetitiveness of the online activities paired with a workbook. The biggest

obstacle Esmeralda faces is keeping up in her mandated core classes because, the classes are all

taught in English and lack a translator, Esmeralda not only has to comprehend the basic English

vocabulary, she must also apply that vocabulary to learning new concepts in subject such as

biology and algebra. It is hard enough learning this new concepts like punnett square and finding

the value for variable in your first language, but it is tremendously more difficult trying to do so

in a language completely foreign. This is the struggle Esmeralda faces every time she steps into a

new class. Aside from the fact that she has to work significantly harder to pass a class, the ESL

instruction which she does receive also obstructs her academic achievement. The program

mandates the English language learners sit in ESL classes for two blocks of allotted time.

Because they may not begin to take regular level English classes until they have tested out of the

ESL program, they fall significantly behind in meeting their minimum graduation requirements.

In order for an individual like Esmerelda to even graduate on time, she must take extra classes

outside of school or over the summer in order to make up for the time lost. Even with the list of

challenges Esmeralda faces, she is still extremely motivated and dedicated. She seeks out

tutoring opportunities and asks for help from Spanish teachers as well as some of her bilingual

peers. Esmeralda is putting forth a tremendous amount of effort so that she may graduate on time

and hopes to continue on to college. Her story is a great example of a student working to break

the language barrier in order to be successful but not all are as fortunate as Esmeralda.

**name changed for privacy reasons

BREAKING THE LANGUAGE BARRIER 13

Issues and Effects on Students

There are various issues that arise when pertaining to the education of children in the

United States, with a limited ability to speak or understand the English language. Because almost

every classroom in this country surrounds students in English-only environments, this leaves

almost 5 million children with the challenge of breaking the language barrier in order to achieve

academically (Sanchez, 2017). These 5 million students rely on the public education system to

provide them with the proper and fundamental resources to improve their English proficiency.

By law, these students possess the right to ESL education, but the public school system is failing

to really provide these students with the necessary resources to thrive. This numerous amount of

students are often forgotten and are forced to face various challenges with little to no aid from

their respective school systems.

Lack of Legislation

One of the most prominent issues that arise when addressing the education of students,

whose first language is not English, has to do with the inadequate laws the country has set

inplace to regulate the public school systems. The problem lays with the dates in which the laws

were established. Legislation such as those previously mentioned are very outdated and there has

been little to no push to either amend said laws or create new legislation. The one thing these

laws and court decision have is that they all merely state that students have the right to receive

ESL education but to do not give specific instructions or guidelines as to how schools must do it.

The vagueness of said laws allows for schools to implement whatever programs they feel like

without paying the necessary attention to how sufficient and the rate of success said programs

have in helping English Language Learners.

Strain on Educators
BREAKING THE LANGUAGE BARRIER 14

The current policies concerning the education of English Language Learners is putting a

particular strain on educators and instructors. The guidelines which school systems place on

teachers puts them in very difficult and inflexible positions. These limits adhere teachers from

catering to each group of student’s needs. One method of instruction cannot be beneficial to each

student in a room because of the high level of diversity of ESL students within each district. A

survey conducting on 2004 of teacher in California stated one of their biggest frustrations is the

lack of ESL educators which then puts the responsibility of providing the proper instruction of 5

million students on a very few number of teachers. They are expected to be able to cater to

students from numerous different countries and backgrounds, each with very different levels of

English proficiency. Another issue addressed within the survey had to do with the lack of

communication between ESL instructors, parents/families, teachers, and administrators who

often make blanket decision pertaining to the ELL’s education without any idea or knowledge

concerning the struggles English Language Learners really face (NEA, 2017).

Methods of Education: English-only vs.Bilingual instruction

The majority of schools in the United States implement English-only classrooms or

instruction for students who are and are not English language learners. The United States Federal

Government does not recognize one official language, but almost 30 states have in fact done so.

Because regulations and policies regarding the education of children is decided by state and local

governments, most have required classroom to teach in strictly English. The said purpose of this

method of instruction is to force English language learners to learn English by completely

immersing them in the language. Those in favor of this method argue that requiring students to

learn in English will push them to learn the language at a faster pace and make them more likely

to blend with their peers who are fluent in the English language. Those opposed to this practice
BREAKING THE LANGUAGE BARRIER 15

state that this method of education is ineffective in its forceful techniques and actually have the

opposite effect than what is intended. By forcing a student who is an English Language Learner

to communicate in a language they may have zero proficiency in, it causes a high degree of

frustration and make them lose their sense of culture or proficiency in their native language.

Another particular issue with this method arises outside of the English intensive ESL instruction.

When English Language Learners join their English speaking peers in their required core

curriculum classes, learning material in subject such as math, science, and social studies is

almost impossible. If a student can barely retain basic English vocabulary terms, they cannot be

expected to retain, for example, mathematical concepts that are difficult enough for a student

whose first language is English. This in turn, causes students to inevitably fall behind

academically (FindLaw, 2017).

Recently, individuals have argued to begin the mass implementation of bilingual or dual

education. This method argues that two-language instruction is the most effective for English

language learners. This method is meant to preserve the language and heritage of a students first

language while teaching the English. According to this practice, students are taught foreign

concepts such a math and science at their appropriate grade level and pace, in their native

language to prevent falling behind in their content based curriculum (Myers, 2014). This method

of education originated in Dades County, Florida, during and right after the Cuban Revolution.

There are many different forms of bilingual education, but this particular form includes teach

English language learners in both English as well as their native language. In elementary level

and even secondary level schools, bilingual or dual education can include applying this method

of teaching to both English and non-English speaking students. Because these students are not

fully developed, they posses more ability to retain instruction in a different language, but at the
BREAKING THE LANGUAGE BARRIER 16

highschool level this becomes more difficult (ProEnglish, 2017). This being said, bilingual

instruction is still extremely beneficial for students who speak a foreign language. It eliminates

the problem of falling behind in their core content classes because they are taught in their native

language. A study of various elementary schools within Texas concluded that students score

significantly higher in standardized math and reading test when receiving bilingual education.

(Michigan State University, 2013). Bilingual education is ideal in providing sufficient resources

for English language learners o thrive academically but becomes difficult to implement in school

who have ELL’s from various different backgrounds.

Impact on Students

The lack of proper legislation, the strain on teachers, and the failure to provide sufficient

resources have a tremendous negative impact on the millions of ESL students that call the United

States their home. These students rely of the public education system to provide them with the

necessary tools to succeed and if the system continues to fail them, English language learners

will be be forced to continue to endure the ramifications. The U.S. Education Department’s

Office of Civil Rights has identified over 120 school districts in which zero students were

enrolled in any sort of ELL program. Within these 121 districts resided over 500,000 students

who did in fact need ESL assistance and received no aid. Aside from these schools which have

violated the existing legislation regarding ESL students, the graduation rate of English Language

Learners has also raised cause for concern. The percentage of English Language Learners who

graduate compared to those with no limited English abilities is significantly lower. The gap

between these two group has ranged anywhere from 10% to a staggering 60% (Sanchez, 2017).

Because of the current practices of our country’s public school, an alarming rate of ELL’s fail

their core subject class and, only about 63% of all ELL’s graduate from high school compared to
BREAKING THE LANGUAGE BARRIER 17

the national graduation rate of 82%. The number of ELL’s who proceed to high educational

institutions is so nominal that very few statistics exist. Another huge gap between those students

with limited English proficiency and their fellow peers can be seen in their standardized test

scores as well as their individual grade reports (NEA, 2017).

Solutions or Alternatives

In order to lessen the severity of the language barrier which affects millions of students

everyday, the proper actions must be taken to aid them in both their designated ESL classes as

well as their inclusive English classrooms. Aside from the high-intensity English instruction they

receive as apart of their ESL education programs, they must integrate and participate in core

subject classes with the rest of the student body, even if they have no reach the necessary level of

English proficiency. To benefit and better aid the students within the time allotted for ESL

education, school systems may begin to explore methods other than the existing English-only

instruction. Teachers must be granted the resources and flexibility to cater their instruction to the

individual students. For example, those teachers who have classes where each ESL student

speaks the same first language, instruction similar to bilingual education should be permitted.

Teachers should not be obligated to teach in ineffective and repetitive ways. Jennifer Gonzalez

lists various methods to help ELL’s succeed in mainstream classrooms. When it is time for

students to leave their ESL classes and enter regular classrooms, they feel insecure and anxious

when being separated from other ELL’s they have become comfortable with. Regular classroom

settings is something that is often times foreign to them and even intimidating. Because those

teachers in regular subject classes may have little to no experience or training when it comes to

educating students with English language proficiency, it has becomes difficult for them to cater

their instruction to benefit these particular student. One of the best ways to ensure you are
BREAKING THE LANGUAGE BARRIER 18

providing a student with limited English capabilities with all the resources they need to succeed

academically is by keeping active and open communication with the student, their ESL

instructor, and the student family. Also, it is very often that ESL students come from foreign

countries seeking refuge in the United States because of some hardships they faced such as

Esmeralda. They may often have no capability to speak or understand English or feel very

anxious. Educator and peers must allow the students to take the time necessary for the culture

shock to pass, and the embarrassment of not being able to speak like those around you. Teachers

may also benefit from making their lessons more visual and implements group work to allow

ELL’s to recieve help from their fellow peers. Another key practice that teachers may partake in

is making sure they learn about the cultural backgrounds of their students in order to better

understand and build a trusting bond with the individual. The most important task of educators

and schools in to create a welcoming community for English Language Learners to prevent them

from feeling like outcasts or burdens (Gonzales, 2014).

Conclusion

Breaking the language barrier is crucial to ensure the success of the millions of the

English Language Learners in the United States. The public school systems failure to provide

adequate resources to these students causes various ramification. A student's ability to succeed

between K-12 as well as in higher educational institutions is severely hindered by the current

ESL programs implemented. The vagueness of legislation, strain on teachers, and inflexibility of

methods are some of the many obstacles that prevent those students with limited English

proficiency levels from thriving academically. The immediate reform of this system is crucial to

guarantee the success of English language learners throughout the country.

BREAKING THE LANGUAGE BARRIER 19

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