In 1998 referendum, voters in California passed Proposition 227 that eliminated bilingual education in California.

ESL students were limited to one year to learn English through 'sheltered English immersion' programs. Thus this proposition denied the parents of non-English speaking students the right to have control over their children's education and created a barrier for ESL students from getting an adequate education. Educators were threatened to be taken to court for not implementing the provisions of this proposition. Passing of Proposition 227 initiative demonstrated the lack of understanding of pedagogical issues by the public and the prevalence of practices that are unwilling to accomodate diversity.