Photo Courtesy of Lovett Weems/United Methodist Focus
United Methodist Focus | May 14, 2026
Stephen Miller, President Trump’s top immigration adviser, wants to know why states pay for the education of undocumented children.
According to reporting by Lauren McGaughy in the New York Times on March 24, 2026, Miller had a closed-door meeting with Texas lawmakers in which Miller asked why Republican-dominated legislatures such as Texas had not passed legislation to fund public education only for children who are citizens or “lawfully present in the United States.” Miller acknowledged that such action would violate the Supreme Court decision in Plyler v. Doe, a 1982 decision that determined that states must pay for the elementary school education of all students regardless of immigration status.
In the mid-1970s, Texas law had been revised to allow the state to withhold from local school districts state funds for educating children of undocumented immigrants. That law stood until it was ruled unconstitutional by the Supreme Court in 1982.
The pivotal Supreme Court decision that guaranteed the education of countless children originated with a ruling by Federal District Judge Woodrow B. Seals in 1980 that it was unconstitutional to deny children of undocumented immigrants access to free public education. It was his decision, along with a similar one by another federal judge, William W. Justice, that made its way to the Supreme Court.
The Supreme Court reasoned that undocumented immigrants and their children, though not citizens of the United States or Texas, are people “in any ordinary sense of the term” and, therefore, are afforded the Fourteenth Amendment protection that a state cannot “deny to any person within its jurisdiction the equal protection of the laws” (Section 1). Since the state law severely disadvantaged these children, by denying them the right to an education, and because Texas could not prove that the regulation was needed to serve a “compelling state interest,” the Court struck down the law. There was a 5-4 decision decided on June 15, 1982.
The current law protecting the education of immigrant children, now being questioned by the President’s top immigration adviser, originated with a decision by a United Methodist Federal District judge whose name few would recognize.
Judge Woodrow B. Seals
Judge Woodrow Seals, Janice Rubin, 1980-02, Performing & Visual Arts Research Collection, University of Houston Libraries Special Collections, University of Houston Digital Collections, https://id.lib.uh.edu/ark:/84475/do4061dk72h
A native of Louisiana, Woodrow Seals (1917-1990) went to law school at the University of Texas and became a lawyer in Houston. During the 1960 presidential campaign, he arranged a pivotal speech by John F. Kennedy to the Greater Houston Ministerial Association, a group of Protestant ministers, to address concerns regarding Kennedy’s Catholic faith. Ethicist Shaun Casey, author of The Making of a Catholic President, says that the meeting, ending with applause, brought to a close “perhaps the single most dramatic public moment in the entire campaign.” Seals was appointed United States Attorney for the Southern District of Texas in 1961 and a United States District Judge in 1966. On the night he received word of his appointment as a federal judge, he was at his church lining up blood donors. The events of that evening illustrate how his public life and his faith life were intimately and appropriately linked.
His local church was St. Stephen United Methodist Church in Houston where it is said he held about every office there was. He was a delegate to annual, jurisdictional, and general conferences and served on denominational general boards. He became the first non-Roman Catholic to receive the Papal Benemerenti Medal, awarded by Pope John Paul II in 1979, for his charitable work with the poor in Houston. Judge Seals received the World Methodist Peace Award from the World Methodist Council in 1987. Perkins School of Theology presents annually the Woodrow B. Seals Laity Award to honor a layperson for outstanding service, faith, and commitment to the church and community.
Wesley, Asbury, Kennedy, and Roosevelt
The connection between his faith life and his life of public service is symbolized by four pictures that were on Judge Seals’s office walls. One wall featured pictures of John F. Kennedy and Franklin D. Roosevelt. On another wall were pictures of John Wesley and Francis Asbury. “I’m not trying to renew the church,” Judge Seals once told me. “I’m trying to renew Woodrow.” He believed that we live in a moral universe and ultimately all social, economic, and political problems can only be solved with attention to the moral realm. He was not enamored with churches passing resolutions asking other people to do things. The church needs to model what it hopes for the world. He remembered what Bishop Fulton Sheen told him once, “It’s hard to understand a leper until you have sat down and held that leper’s hand.”
As much as Judge Seals sought to live out his faith in the world, he had no time for those who sought to merge church and state. He felt that notions of a Christian nation were inaccurate and not helpful. Instead, a realistic assessment of the country would find that the pervasive value over the years has been a culture of violence. He believed that being at war “half the time we have been a nation” creates that atmosphere of violence.
Unfortunately, Stephen Miller and his associates must know nothing of faith traditions that nurtured and shaped Woodrow Seals. How tragic that many in the nation’s leadership and their priorities have changed so much since a judge appropriately linked his public life and his faith life. And how much more we see that change in the past decade. Miller may convince Texas legislators to pass legislation, clearly now unconstitutional, to deny education funding for children without legal standing. If so, the current Supreme Court may very well uphold such a law.
References
“perhaps the single most….” Shaun A. Casey, The Making of a Catholic President (New York: Oxford University Press, 2009), 175.
Woodrow Seals’s quotations are from an interview published in Lovett H. Weems, Jr., “The Influence of the Church Upon My Life: Interviews with United Methodists” (Nashville: Discipleship Resources, 1976), 65-70.
For more information:
Woodrow B. Seals Laity Award, Perkins School of Theology
JFK Address to the Greater Houston Ministerial Association (September 12, 1960)
Fourteenth Amendment to the U.S. Constitution
The Rev. Lovett H. Weems Jr.
Wesley Theological Seminary Photo
United Methodist Focus is the Substack blog of the Rev. Dr. Lovett H. Weems, Jr., distinguished professor of church leadership emeritus at Wesley Theological Seminary in Washington, DC. He came to Wesley in 2003 as the founding director of the Wesley’s Lewis Center for Church Leadership after eighteen years as president of Saint Paul School of Theology in Kansas City. Previously he was a pastor in Mississippi for many years. He is the author of many books on church leadership that have had a broad appeal to a large constituency of leaders in both the public and private sectors.