Introduction The education of immigrant students, in the United States, up until the early 1970s, was one of "sink or swim" policy with students having to assimilate as quickly as possible with no language support or transitional period in their own native language. The Lau vs. Nichols (1974) court case was the landmark case that initiated the beginnings of English as a Second Language (ESL) classrooms as well as bilingual education as it is today. Now, immigrant and non-English-speaking students are given the opportunity to spend time in a "sheltered" ESL classroom with intense English language instruction until they have adequate English language skills to survive in the regular mainstream classroom with English speakers.
