The history of case-making for foreign language (FL) study in high schools and colleges in the United States is surveyed. The cognitive development case, which historically adhered to a faculty theory of psychology, emphasized the applicability of FL study as mental discipline. Though this notion has been in decline, educators are now looking favorably at the possible benefits of FL study for performance in selected areas, especially native language skills. The controversy in the early part of this century over whether mental training or information was the proper subject of schooling gave rise to the utilitarian case--"education for social efficiency." The notion, still alive, that foreign languages are taught because it is necessary to be able to use them, demands specific policies in program development to meet practical goals. Finally, the cultural case, which also came into vogue at the turn of the century, has evolved from an emphasis on formal aspects of foreign culture to one of contextualizing language study as a practical necessity. It is maintained that research should investigate the potential fruitfulness of each of these points of view for effective planning by present-day educators. (JB)