Currently experiencing a demographic shift in the student population, the public school system has seen an influx of ELLs (English Language Learners) within the student population with the vast majority being speakers of Spanish, and the issue has arisen of how best to educate these students to acquire English as an additional language. Amongst the states with higher concentrations of ELLs, the state of Arizona once gave relatively free reign on the education of ELLs which subsequently resulted in wide disparities in qualities due to both lack of teacher preparation and funding, and this resulted in the 2000 case of Flores vs. Arizona which validated the claims that the state failed to provide adequate funding and resources to the education of ELLs. In accordance with the ruling, Arizona passed Proposition 203 which mandated that ELLs be taught solely in English, and this is reflective of restrictive language policy. Though implemented for a short time, this review discussed how restrictive language programs can be detrimental to student achievement, and proposed bilingual education as an alternative to spur student literacy and achievement. Evidenced by the case studies of France, Spain, and other states with the latter two shifting towards bilingual education, the review discussed the implications of France's apprehension to bilingual education and the others implementing it. Finding that bilingual education proved to be more the better choice of the two language programs with consideration of two-way immersion rather than one-way, the review also proposes a sample model that could be used in Arizona, and this is based upon models utilized in Spain and other states with evident benefits which are juxtaposed to France's prolonged use of language restriction.