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==School voucher public policy in the United States== {{Education in the U.S.}} In the 1980s, the Reagan administration pushed for vouchers, as did the George W. Bush administration in the initial education reform proposals leading up to the [[No Child Left Behind Act]]. As of December 2016, 14 states had traditional school voucher programs.<ref name=":5">{{Cite web |last=Legislatures |first=National Conference of State |title=Interactive Guide to School Choice Laws |url=http://www.ncsl.org/research/education/interactive-guide-to-school-choice.aspx#/ |access-date=2018-04-25 |website=www.ncsl.org |language=en-US |archive-date=April 15, 2018 |archive-url=https://web.archive.org/web/20180415165619/http://www.ncsl.org/research/education/interactive-guide-to-school-choice.aspx#/ |url-status=dead }}</ref> These states consist of: Arkansas, Florida, Georgia, Indiana, Louisiana, Maine, Maryland, Mississippi, North Carolina, Ohio, Oklahoma, Utah, Vermont, and Wisconsin. The capital of the United States, [[Washington, D.C.]], also had operating school voucher programs as of December 2016.<ref name=":5" /> When including scholarship tax credits and education savings accounts β two alternatives to vouchers β there are 27 states plus the District of Columbia with private school choice programs. Most of these programs were offered to students in low-income families, low-performing schools, or students with disabilities. By 2014, the number participating in either vouchers or tax-credit scholarships increased to 250,000, a 30% increase from 2010, but still a small fraction compared to the 55 million in traditional schools.<ref name="politico">{{Cite news |last=Stephanie |first=Simon |date=2014-03-24 |title=Special report: Taxpayers fund creationism in the classroom |url=http://www.politico.com/story/2014/03/education-creationism-104934.html |access-date=24 February 2015}}</ref> In 1990, the city of [[Milwaukee|Milwaukee, Wisconsin]]'s [[Milwaukee Public Schools|public schools]] implemented a program called the Milwaukee Parental Choice Program. Originally, this funded school vouchers for nonreligious, private institutions. It was, however, eventually expanded to include private, religious institutions after it saw success with nonreligious, private institutions.<ref>{{Cite journal |last1=Carlson |first1=D. D. |last2=Cowen |first2=O. J. |year=2015 |title=School Vouchers and Student Neighborhoods: Evidence from the Milwaukee Parental Choice Program |journal=Education Policy Analysis Archives |volume=23 |issue=60/61 |pages=1β24 |doi=10.14507/epaa.v23.1930 |doi-access=free}}</ref> The 2006/07 school year marked the first time in Milwaukee that more than $100 million was paid in vouchers.<ref>{{Cite web |title=Vouchers to Pass $100 Million Mark, Milwaukee Journal Sentinel, November 21, 2006 |url=http://www.jsonline.com/story/index.aspx?id=533306 |access-date=November 21, 2006}}</ref> Twenty-six percent of Milwaukee students will receive public funding to attend schools outside the traditional Milwaukee Public School system. In fact, if the voucher program alone were considered a school district, it would mark the sixth-largest district in Wisconsin. [[St. Anthony High School (Milwaukee)|St. Anthony Catholic School]], located on Milwaukee's south side, boasts 966 voucher students, meaning that it very likely receives more public money for general school support of a parochial elementary or high school than any before it in American history. A 2013 study of Milwaukee's program posited that the use of vouchers increased the probability that a student would graduate from high school, go to college, and stay in college.<ref name="EdWeek">{{Cite news |date=August 11, 2011 |title=Vouchers |work=Education Week |url=http://www.edweek.org/ew/issues/vouchers/ |access-date=July 17, 2015}}</ref> A 2015 paper published by the [[National Bureau of Economic Research]] found that participation in Louisiana's voucher program "substantially reduces academic achievement" although that the result may be reflective of the poor quality of private schools in the program.<ref name="EdWeek" /> A recent analysis of the competitive effects of school vouchers in Florida suggests that more competition improves performance in the regular public schools.<ref>{{Cite journal |last1=Figlio |first1=David |last2=Hart |first2=Cassandra M. D. |year=2014 |title=Competitive Effects of Means-Tested School Vouchers |url=http://www.aeaweb.org/aej/app/app/0601/2012-0019_app.pdf |journal=American Economic Journal: Applied Economics |volume=6 |issue=1 |pages=133β56 |doi=10.1257/app.6.1.133 |s2cid=16232262}}</ref> The largest school voucher program in the United States is the [[Indiana Choice Scholarships]] program. ===Opponents=== The main critique of school vouchers and education tax credits is that they put public education in competition with private education, threatening to reduce and reallocate public school funding to private schools. Opponents question the belief that private schools are more efficient. Public school teachers and teacher unions have also fought against school vouchers. In the United States, public school teacher unions,<ref>{{Cite news |last=Bender |first=Michael C. |date=June 13, 2008 |title=Local News: West Palm Beach, Palm Beach County, Martin & St. Lucie Counties |work=The Palm Beach Post |url=http://www.palmbeachpost.com/state/content/state/epaper/2008/06/13/0613constitutionalamendments.html |access-date=August 11, 2011}}</ref> most notably the [[National Education Association]] (the largest labor union in the US), argue that school vouchers erode educational standards and reduce funding and that giving money to parents who choose to send their child to a religious or other school is unconstitutional. The latter issue was struck down by the [[Supreme Court of the United States|Supreme Court]] case ''[[Zelman v. Simmons-Harris]]'', which upheld Ohio's voucher plan in a 5β4 ruling.<ref>{{Cite web |title=Getting an Education - The Voucher Controversy - School, Public, Schools, Charter, Private, and Vouchers |url=http://www.libraryindex.com/pages/1661/Getting-an-Education-VOUCHER-CONTROVERSY.html |url-status=dead |archive-url=https://web.archive.org/web/20110727075759/http://www.libraryindex.com/pages/1661/Getting-an-Education-VOUCHER-CONTROVERSY.html |archive-date=July 27, 2011 |access-date=August 11, 2011 |publisher=Libraryindex.com}}</ref><ref>{{Cite web |date=October 30, 2008 |title=Vouchers |url=http://www.nea.org/home/16378.htm |access-date=August 11, 2011 |publisher=NEA}}</ref><ref>{{Cite web |date=November 13, 2008 |title=List of NEA beliefs and legal fights against vouchers |url=http://www.nea.org/home/19133.htm |url-status=dead |archive-url=https://web.archive.org/web/20110807093324/http://www.nea.org/home/19133.htm |archive-date=August 7, 2011 |access-date=August 11, 2011 |publisher=Nea.org}}</ref> In contrast, the use of public-school funding for vouchers to private schools was disallowed by the Louisiana Supreme Court in 2013. The Louisiana Supreme Court did not declare vouchers unconstitutional, just the use of money earmarked for public schools via the Louisiana Constitution for funding Louisiana's voucher program.<ref>{{Cite news |last=Strauss |first=Valerie |date=May 7, 2013 |title=Louisiana Supreme Court rules school voucher funding unconstitutional |newspaper=Washington Post |url=https://www.washingtonpost.com/blogs/answer-sheet/wp/2013/05/07/louisiana-supreme-court-rules-school-voucher-funding-unconstitutional/}}</ref> The [[National Education Association]] also points out that access to vouchers is just like "a chance in a lottery" where parents had to be lucky to get a space in this program. Since almost all students and their families would like to choose the best schools, those schools, as a result, quickly reach its maximum capacity number for students that state law permits. Those who did not get vouchers then have to compete again to look for some other less preferred and competitive schools or give up searching and go back to their assigned local schools.<ref>{{Cite web |last=Pons |first=Michael |title=School Vouchers: The Emerging Track Record |url=http://www.nea.org/home/16970.htm |url-status=dead |archive-url=https://web.archive.org/web/20130304095505/http://www.nea.org/home/16970.htm |archive-date=March 4, 2013 |access-date=November 20, 2012 |publisher=National Education Association}}</ref> [[Jonathan Kozol]], a prominent public school reform thinker and former public-school teacher called vouchers the "single worst, most dangerous idea to have entered education discourse in my adult life".<ref>Lisa Kaiser, "[http://www.expressmilwaukee.com/article-5728-an-interview-with-educator-and-activist-jonathan-kozol.html An Interview with Educator and Activist Jonathan Kozol] {{Webarchive|url=https://web.archive.org/web/20100209211830/http://www.expressmilwaukee.com/article-5728-an-interview-with-educator-and-activist-jonathan-kozol.html |date=February 9, 2010 }}", March 4, 2009, Express Milwaukee.com</ref> The [[National Education Association]] additionally argues that more money should go towards [[public education]] to help the schools struggling and improve the schools overall, instead of reducing the public school's fund to go towards school vouchers.<ref name=":7">{{Cite news |title=The Case Against Vouchers |language=en |work=NEA |url=http://www.nea.org/home/19133.htm |url-status=dead |access-date=2018-04-25 |archive-url=https://web.archive.org/web/20090419231358/http://www.nea.org/home/19133.htm |archive-date=April 19, 2009}}</ref> Their argument claims that increasing that amount of money that goes towards public education would also increase the amount of resources put into public schools, therefore, improving the education.<ref name=":7" /> This argument made towards school vouchers reflects the way the organization values public education. For example, in an interview in May 2017 regarding [[Donald Trump]]'s 2018 Budget Proposal, the organization's president, [[Lily Eskelsen GarcΓa]], claimed: "We should invest in what makes schools great, the things that build curiosity and instill a love of learning. That is what every student deserves and what every parent wants for his or her child. It should not depend on how much their parents make, what language they speak at home, and certainly, not what neighborhood they live in." β National Education Association President [[Lily Eskelsen GarcΓa]].<ref>{{Cite news |title=NEA President: Trump-DeVos budget is a wrecking ball aimed at public schools |language=en |work=NEA |url=http://www.nea.org/home/70780.htm |url-status=dead |access-date=2018-04-25 |archive-url=https://web.archive.org/web/20180425183207/http://www.nea.org/home/70780.htm |archive-date=April 25, 2018}}</ref> Furthermore, there are multiple studies that support the arguments made by opponents of school vouchers. One of these studies, conducted by the [[Tulane University]]'s Education Research Alliance, consists of observing the relationship between voucher programs and students' test scores. They found that students in the Louisiana voucher program initially had lower test scores, but after three years, their scores matched those of students who stayed in public schools from standardized test scores spanning from 2012 to 2015.<ref>{{Cite magazine |title=Here's Why Researchers Say Betsy DeVos' Proposed School Voucher Program Won't Work |url=https://time.com/4832923/betsy-devos-trump-administration-school-choice-vouchers/ |magazine=Time |language=en |access-date=2018-04-25}}</ref> People who can benefit from vouchers may not know it. In April 2012, a bill passed in Louisiana that made vouchers available to low-income families whose children attended poorly ranked schools. A student whose household income was low (up to about $44,000 for a family of three) and who attended a school ranked "C", "D", or "F" could apply for vouchers to attend another.<ref>{{Cite web |title=See Tidmore, C. (2012, April 10). Voucher bill passes |url=http://www.louisianaweekly.com/voucher-bills-pass/}}</ref> Of the estimated 380,000<ref>{{Cite news |last=Mooney |first=K. |date=March 12, 2012 |title=Louisiana legislature prepares to debate expansion of voucher program |work=The Pelican Post |url=http://www.thepelicanpost.org/2012/03/12/louisiana-legislature-prepares-to-debate-expansion-of-voucher-program/ |archive-url=https://web.archive.org/web/20131014214604/http://www.thepelicanpost.org/2012/03/12/louisiana-legislature-prepares-to-debate-expansion-of-voucher-program/ |archive-date=October 14, 2013}}</ref> eligible students during the school year when the bill was passed (2012/13), only 5,000 students knew about and applied for the vouchers, and accepted them.<ref>Louisiana State Department of Education website for its Louisiana Scholarship program.[http://www.louisianabelieves.com/schools/louisiana-scholarship-program]</ref> In 2006, the [[United States Department of Education]] released a report concluding that average test scores for reading and mathematics, when adjusted for student and school characteristics, tend to be very similar among public schools and private schools. Private schools performed significantly better than public schools only if results were not adjusted for factors such as race, gender, and free or reduced-price lunch program eligibility.<ref>{{Cite web |date=July 14, 2006 |title=Comparing Private Schools and Public Schools Using Hierarchical Linear Modeling |url=http://nces.ed.gov/pubsearch/pubsinfo.asp?pubid=2006461 |access-date=August 11, 2011 |publisher=Nces.ed.gov}}</ref> Other research questions assumptions that large improvements would result from a more comprehensive voucher system.<ref>{{Cite web |date=August 2008 |title=School Vouchers and Student Achievement: Recent Evidence, Remaining Questions |url=http://www.chicagofed.org/digital_assets/publications/working_papers/2008/wp2008_08.pdf |website=Federal Reserve Bank of Chicago}}</ref> Given the limited budget for schools, it is claimed that a voucher system would weaken public schools while not providing enough money for people to attend [[private school]]s. 76% of the money given in Arizona's voucher program went to children already in private schools.<ref>{{Cite book |last=Palast |first=Greg |url=https://archive.org/details/armedmadhousewho00pala |title=Armed Madhouse (No Child's Behind Left) |publisher=Dutton Adult |year=2006 |isbn=978-0-525-94968-8 |url-access=registration}}</ref> Some sources claim that public schools' higher per-pupil spending is due to having a higher proportion of students with behavioral, physical, and emotional problems since in the United States, public schools must by law accept any student regardless of race, gender, religion, disability, educational aptitude, and so forth, while private schools are not so bound. They argue that some, if not all, of the cost difference between public and private schools comes from "[[cream skimming]]", whereby the private schools select only those students who belong to a preferred group β whether economic, religious, educational aptitude level, or ethnicity β rather than from differences in administration.<ref>{{Cite web |title=What Would A School Voucher Buy The Real Cost Of Private Schools |url=http://www.cato.org/pubs/briefs/bp-025.html |access-date=August 11, 2011 |publisher=Cato.org}}</ref><ref>{{Cite web |date=October 28, 2007 |title=Are Private Schools More Cost Effective Than Public Ones? |url=http://economics.about.com/b/2007/10/28/are-private-schools-more-cost-effective-than-public-ones.htm |access-date=August 11, 2011 |publisher=Economics.about.com |archive-date=August 7, 2011 |archive-url=https://web.archive.org/web/20110807101339/http://economics.about.com/b/2007/10/28/are-private-schools-more-cost-effective-than-public-ones.htm |url-status=dead }}</ref> The result, it has been argued, is that a voucher system has led or would lead students who do not belong to the private schools' preferred groupings to become concentrated at public schools.<ref>{{Cite news |last1=Goodkin |first1=Susan |last2=Gold |first2=David G. |date=August 27, 2007 |title=The Gifted Children Left Behind |newspaper=[[Washington Post]] |url=https://www.washingtonpost.com/wp-dyn/content/article/2007/08/26/AR2007082600909.html |access-date=August 27, 2007}}</ref> However, of the ten state-run voucher programs in the United States at the beginning of 2011, four targeted low-income students, two targeted students in failing schools, and six targeted students with special needs. (Louisiana ran a single program targeting all three groups.)<ref>{{Cite journal |last=Campanella |first=Andrew |date=2011 |title=Hope for America's Children (School Choice Yearbook 2010β11) |url=https://s3.amazonaws.com/AFC/scy2011.pdf |publisher=Alliance for School Choice |access-date=May 23, 2012 |archive-date=June 17, 2013 |archive-url=https://web.archive.org/web/20130617012815/https://s3.amazonaws.com/AFC/scy2011.pdf |url-status=dead }}</ref> It is also argued that voucher programs are often implemented without the necessary safeguards that prevent institutions from discriminating against marginalized communities. In the United States, as of 2016, there are currently no state laws that require voucher programs to not discriminate against marginalized communities.<ref>{{Cite journal |last1=Eckes |first1=Suzanne E. |last2=Mead |first2=Julie |last3=Ulm |first3=Jessica |date=29 June 2016 |title=Dollars to Discriminate: The (Un)intended Consequences of School Vouchers |journal=Peabody Journal of Education |volume=91 |issue=4 |pages=537β558 |doi=10.1080/0161956X.2016.1207446 |s2cid=156577104}}</ref> Further, while some voucher programs may explicitly be aimed at marginalized communities, this is not necessarily always the case. A common argument for school vouchers is that it allows for marginalized communities of color to be uplifted from poverty. Historically, however, data suggests that voucher programs have been used to further segregate Americans.<ref>{{Cite journal |last1=Gooden |first1=Mark A. |last2=Jabbar |first2=Huriya |last3=Torres, Jr. |first3=Mario S. |date=29 June 2016 |title=Race and school vouchers: legal, historical, and political contexts |journal=Peabody Journal of Education |volume=91 |issue=4 |pages=522β536 |doi=10.1080/0161956X.2016.1207445 |s2cid=147762358}}</ref> Further, some data has shown that the effects of voucher programs such as the New York City School Choice Scholarship Program, are marginal when it comes to increasing student achievement.<ref>{{Cite journal |last1=Bitler |first1=Marianne |last2=Domina |first2=Thurston |last3=Penner |first3=Emily |last4=Hoynes |first4=Hilary |date=24 July 2014 |title=Distributional analysis in educational evaluation: a case study from the New York City Voucher Program |journal=Journal of Research on Educational Effectiveness |volume=8 |issue=3 |pages=419β450 |doi=10.1080/19345747.2014.921259 |pmc=4507830 |pmid=26207158}}</ref> Another argument against a school voucher system is its lack of accountability to taxpayers. In many states, members of a community's board of education are elected by voters. Similarly, a school budget faces a referendum. Meetings of the Board of Education must be announced in advance, and members of the public are permitted to voice their concerns directly to board members. By contrast, although vouchers may be used in private and religious schools, taxpayers cannot vote on budget issues, elect members of the board or even attend board meetings. Even voucher proponents acknowledge that decreased transparency and accountability for public funds are problematic features of the voucher system, and some have suggested a 'sliding scale' approach wherein oversight and accountability increase in proportion to the number of taxpayer dollars (in the form of vouchers) received by the private school.<ref>{{Cite web |last1=Petrilli |first1=Michael J. |last2=Finn, Chester E. |last3=Hentges, Christina |last4=Northern, Amber M. |date=2009 |title=When Private Schools Take Public Dollars: What's the Place of Accountability in School Voucher Programs? |url=https://fordhaminstitute.org/national/research/when-private-schools-take-public-dollars-whats-place-accountability-school |publisher=Thomas B. Fordham Institute}}</ref> [[Kevin G. Welner|Kevin Welner]] points out that vouchers funded through a convoluted tax credit system β a policy he calls "neovouchers" β present additional accountability concerns. With neovoucher systems, a taxpayer owing money to the state instead donates that money to a private, nonprofit organization. That organization then bundles donations and gives them to parents as vouchers to be used for private school tuition. The state then steps in and forgives (through a tax credit) some or all of the taxes that the donor has given to the organization. While conventional tax credit systems are structured to treat all private school participants equally, neovoucher systems effectively delegate to individual private taxpayers (those owing money to the state) the power to decide which private schools will benefit.<ref>{{Cite book |last=Welner |first=Kevin G. |title=NeoVouchers: The Emergence of Tuition Tax Credits for Private Schooling |date=2008 |publisher=Rowman & Littlefield |isbn=978-0742540804}}</ref> An example of a lack of accountability is the voucher situation in Louisiana. In 2012, Louisiana State Superintendent of Education John White selected private schools to receive vouchers, then tried to fabricate criteria (including site visits) after schools had already received approval letters. One school of note, New Living Word in Ruston, Louisiana, did not have sufficient facilities for the over 300 students White and the state board of education had approved.<ref>See Leader, Barbara (July 2, 2012). Email exchange reveals voucher scheme. [http://www.thenewsstar.com/article/20120702/NEWS01/207020308/Email-exchange-reveals-voucher-scheme] {{Webarchive|url=https://web.archive.org/web/20130804022132/http://www.thenewsstar.com/article/20120702/NEWS01/207020308/Email-exchange-reveals-voucher-scheme|date=August 4, 2013}}</ref> Following a voucher audit in 2013, New Living Word had overcharged the state $395,000. White referred to the incident as a "lone substantive issue".<ref>{{Cite news |last=Sentell |first=Will |date=June 30, 2013 |title=Ruston school banned from accepting voucher students |work=[[The Advocate (Stamford)|The Advocate]] |url=http://theadvocate.com/home/6377589-125/ruston-school-banned-from-accepting |archive-url=https://web.archive.org/web/20131015044643/http://theadvocate.com/home/6377589-125/ruston-school-banned-from-accepting |archive-date=2013-10-15}}</ref> However, most voucher schools did not undergo a complete audit for not having a separate checking account for state voucher money.<ref>{{Cite web |last=White, Jr |first=Lamar |date=July 8, 2013 |title=Audit reveals systemic, widespread problems in Louisiana's school voucher program |url=https://cenlamar.com/2013/07/08/audit-reveals-systemic-widespread-problems/ |website=CenLamar}}</ref> According to Susanne Wiborg, an expert on comparative education, Sweden's voucher system introduced in 1992 has "augmented social and ethnic segregation, particularly in relation to schools in deprived areas".<ref>{{Cite news |last=Richardson |first=Hannah |date=July 22, 2010 |title=Free schools 'could widen social divide' |work=[[BBC News Online]] |url=https://www.bbc.co.uk/news/education-10725724}}</ref> Tax-credit scholarships which are in most part disbursed to current private school students or to families which made substantial donations to the scholarship fund, rather than to low-income students attempting to escape from failing schools, amount to nothing more than a mechanism to use public funds in the form of foregone taxes to support private, often religiously based, private schools.<ref name="NYTBD" /> ===Proponents=== Proponents of school vouchers and education tax credit systems argue that those systems promote [[free market]] competition among both private and public schools by allowing parents and students to choose the school to use the vouchers. This choice available to parents' forces schools to perpetually improve to maintain enrollment. Thus, proponents argue that a voucher system increases school performance and accountability<ref>{{Cite web |title=Roads, Education, and Waterways: The Case Against Public Services - Mises Media |url=https://mises.org/media/2349/Roads-Education-and-Waterways-The-Case-Against-Public-Services |url-status=dead |archive-url=https://web.archive.org/web/20110922044340/http://mises.org/media/2349/Roads-Education-and-Waterways-The-Case-Against-Public-Services |archive-date=September 22, 2011}}</ref> because it provides [[consumer sovereignty]] β allowing individuals to choose what product to buy, as opposed to a [[Public administration|bureaucracy]].<ref>{{Cite web |title=Dollar Voting |url=http://ingrimayne.com/econ/AllocatingRationing/DollarVoting.html |website=ingrimayne.com}}</ref><ref>{{Cite web |title=Majority Rule |url=http://ingrimayne.com/econ/government/MajorityRule.html |website=ingrimayne.com}}</ref> This argument is supported by studies such as "When Schools Compete: The Effects of Vouchers on Florida Public School Achievement" ([[Manhattan Institute for Policy Research]], 2003), which concluded that public schools located near private schools that were eligible to accept voucher students made significantly more improvements than did similar schools not located near eligible private schools. Stanford's [[Caroline Hoxby]], who has researched the systemic effects of school choice, determined that areas with greater residential school choice have consistently higher test scores at a lower per-pupil cost than areas with very few school districts.<ref name="hoxby1998" /> Hoxby studied the effects of vouchers in Milwaukee and of charter schools in Arizona and Michigan on nearby public schools. Public schools forced to compete made greater test-score gains than schools not faced with such competition,<ref name="hoxby2001" /> and that the so-called effect of [[cream skimming]] did not exist in any of the voucher districts examined. Hoxby's research has found that both private and public schools improved through the use of vouchers.<ref name="hoxby1998">Hoxby, Caroline "Analyzing School Choice Reforms that Use America's Traditional Forms of Parental Choice" in Paul E. Peterson and Bryan C. Hassel eds., Learning from School Choice, Brookings Institution, 1998.</ref><ref name="hoxby2001">Hoxby, Caroline, "Rising Tide" Education Next, Winter, 2001.</ref><ref>{{Cite web |date=March 14, 2001 |title=Education Working Paper 2 | When Schools Compete: The Effects of Vouchers on Florida Public School Achievement |url=http://www.manhattan-institute.org/html/ewp_02.htm |access-date=August 11, 2011 |publisher=Manhattan-institute.org}}</ref><ref name="chap06">{{Cite web |title=chap06.choice |url=http://www.allianceforschoolchoice.org/UploadedFiles/ResearchResources/Competition-%20Hoxby.pdf |url-status=dead |archive-url=https://web.archive.org/web/20110809100251/http://www.allianceforschoolchoice.org/UploadedFiles/ResearchResources/Competition-%20Hoxby.pdf |archive-date=August 9, 2011 |access-date=August 11, 2011 |df=mdy-all}}</ref> Similarly, it is argued that such competition has helped in higher education, with publicly funded universities directly competing with private universities for tuition money provided by the Government, such as the [[GI Bill]] and the [[Pell Grant]] in the United States. The [[Foundation for Educational Choice]] alleges that a school voucher plan "embodies exactly the same principle as the GI bills that provide for educational benefits to military veterans. The veteran gets a voucher good only for educational expense and he is completely free to choose the school at which he uses it, provided that it satisfies certain standards".<ref>{{Cite web |title=Our Legacy |url=https://www.edchoice.org/who-we-are/our-legacy/ |website=EdChoice}}</ref> The Pell Grant, a need-based aid, like the Voucher, can only be used for authorized school expenses at qualified schools, and, like the Pell, the money follows the student, for use against those authorized expenses (not all expenses are covered).<ref name="PELL">{{Cite web |title=Federal Pell Grants are usually awarded only to undergraduate students. |url=https://studentaid.ed.gov/sa/types/grants-scholarships/pell |access-date=March 10, 2017}}</ref><ref name="HowCalculated">{{Cite web |title=Wondering how the amount of your federal student aid is determined? |url=https://studentaid.ed.gov/sa/fafsa/next-steps/how-calculated |access-date=March 10, 2017}}</ref> Proponents are encouraged by private school sector growth, as they believe that private schools are typically more efficient at achieving results at a much lower per-pupil cost than public schools. A [[CATO Institute]] study of public and private school per pupil spending in Phoenix, Los Angeles, D.C., Chicago, New York City, and Houston found that public schools spend 93% more than the estimated median private schools.<ref name=":0">{{Cite web |last=Schaeffer |first=Adam |year=2010 |title=They Spend WHAT? (The Real Cost of Public Schools) |url=http://www.cato.org/pub_display.php?pub_id=11432 |publisher=Cato Institute}}</ref> Proponents claim that institutions often are forced to operate more efficiently when they are made to compete<ref name=chap06/> and that any resulting job losses in the public sector would be offset by the increased demand for jobs in the private sector.<ref>{{Cite web |last=Forster |first=Greg |title=Lost Opportunity: An Empirical Analysis of How Vouchers Affected Florida Public Schools |url=https://www.edchoice.org/wp-content/uploads/2015/09/Lost-Opportunity-How-Vouchers-Affected-Florida-Public-Schools.pdf |access-date=30 August 2022}}</ref> [[Friedrich von Hayek]] on the privatizing of education: {{blockquote|As has been shown by Professor Milton Friedman (M. Friedman, The role of government in education, 1955), it would now be entirely practicable to defray the costs of general education out of the public purse without maintaining government schools, by giving the parents vouchers covering the cost of education of each child which they could hand over to schools of their choice. It may still be desirable that government directly provide schools in a few isolated communities where the number of children is too small (and the average cost of education therefore too high) for privately run schools. But with respect to the great majority of the population, it would undoubtedly be possible to leave the organization and management of education entirely to private efforts, with the government providing merely the basic finance and ensuring a minimum standard for all schools where the vouchers could be spent. (F. A. Hayek, in his 1960 book [[The Constitution of Liberty]], section 24.3)}} Other notable supporters include New Jersey Senator [[Cory Booker]], former governor of South Carolina [[Mark Sanford]],<ref>{{Cite web |title=SC Biz News |url=http://www.charlestonbusiness.com/pub/6_2/news/2771-1.html |archive-url=https://web.archive.org/web/20070929003630/http://www.charlestonbusiness.com/pub/6_2/news/2771-1.html |archive-date=September 29, 2007 |website=www.charlestonbusiness.com}}</ref> billionaire and American philanthropist [[John T. Walton]],<ref>{{Cite web |title=Godspeed John Walton |url=http://www.blackfive.net/main/2005/06/godspeed_john_w.html |access-date=August 11, 2011 |publisher=Blackfive}}</ref> Former mayor of Baltimore [[Kurt L. Schmoke]],<ref>{{Cite web |date=August 20, 1999 |title=Civic Bulletin 20 | Why School Vouchers Can Help Inner-City Children, by The Honorable Kurt L. Schmoke |url=http://www.manhattan-institute.org/html/cb_20.htm |access-date=August 11, 2011 |publisher=Manhattan-institute.org}}</ref> Former Massachusetts Governor [[Mitt Romney]]<ref>{{Cite web |title=Candidate - Mitt Romney |url=http://www.ourcampaigns.com/CandidateDetail.html?CandidateID=2075 |access-date=August 11, 2011 |publisher=Our Campaigns}}</ref> and [[John McCain]].<ref>{{Cite web |title=U.S. Senator John McCain |url=http://mccain.senate.gov/press_office/view_article.cfm?id=587 |archive-url=https://web.archive.org/web/20071101081939/http://mccain.senate.gov/press_office/view_article.cfm?id=587 |archive-date=November 1, 2007 |website=mccain.senate.gov}}</ref> A random survey of 210 Ph.D.-holding members of the [[American Economic Association]], found that over two-thirds of economists support giving parents educational vouchers that can be used at government-operated or privately operated schools, and that support is greater if the vouchers are to be used by parents with low-incomes or parents with children in poorly performing schools.<ref name="auto">{{Cite journal |last=Whaples |first=Robert |date=2006 |title=Do Economists Agree on Anything? Yes! |url=http://ew-econ.typepad.fr/articleAEAsurvey.pdf |journal=[[The Economists' Voice]] |volume=3 |issue=9 |pages=1β6 |doi=10.2202/1553-3832.1156 |access-date=January 6, 2016 |s2cid=201123406}}</ref> Another prominent proponent of the voucher system was [[Apple Inc.|Apple]] co-founder and CEO, [[Steve Jobs]], who said:<ref>{{Cite magazine |last=Wolf |first=Gary |date=February 1996 |title=Steve Jobs: The Next Insanely Great Thing (The Wired Interview) |url=https://www.wired.com/wired/archive/4.02/jobs_pr.html |magazine=[[Wired (magazine)|Wired]] |access-date=February 8, 2014}}</ref> {{blockquote| The problem is bureaucracy. I'm one of these people who believes the best thing we could ever do is go to the full voucher system. I have a 17-year-old daughter who went to a private school for a few years before high school. This private school is the best school I've seen in my life. It was judged one of the 100 best schools in America. It was phenomenal. The tuition was $5,500 a year, which is a lot of money for most parents. But the teachers were paid less than public school teachers β so it's not about money at the teacher level. I asked the state treasurer that year what California pays on average to send kids to school, and I believe it was $4,400. While there are not many parents who could come up with $5,500 a year, there are many who could come up with $1,000 a year. If we gave vouchers to parents for $4,400 a year, schools would be starting right and left. People would get out of college and say, "Let's start a school." |sign=[[Steve Jobs]]<ref>{{Cite magazine |last=Wolf |first=Gary |title=Steve Jobs: The Next Insanely Great Thing |url=https://www.wired.com/1996/02/jobs-2/ |magazine=Wired |via=www.wired.com}}</ref>}} As a practical matter, proponents{{Who|date=February 2025}} note, most U.S. programs only offer poor families the same choice more affluent families already have, by providing them with the means to leave a failing school and attend one where the child can get an education. Because public schools are funded on a per-pupil basis, the money simply follows the child, but the cost to taxpayers is less because the voucher generally is less than the actual cost.{{Citation needed|date=February 2025}} In addition, they{{Who|date=February 2025}} say, the comparisons of public and private schools on average are meaningless. Vouchers usually are used by children in failing schools, so they can hardly be worse off even if the parents fail to choose a better school.{{Citation needed|date=February 2025}} Also, focusing on the effect on public school suggests that is more important than the education of children.{{Citation needed|date=February 2025}} Some proponents of school vouchers, including the [[Sutherland Institute]] and many supporters of the Utah voucher effort, see it as a remedy for the negative cultural impact caused by underperforming public schools, which falls disproportionately on demographic minorities.<ref>{{Cite web |title=Christine Cook, Sutherland Institute, "It is time for Utah to offer true educational choice". ''Davis County Clipper'', April 20, 2017, A5. |url=https://davisclipper.com/clients/davisclipper/April202017.pdf |url-status=dead |archive-url=https://web.archive.org/web/20200206152457/https://davisclipper.com/clients/davisclipper/April202017.pdf |archive-date=February 6, 2020}}</ref> During the run-up to the November referendum election, Sutherland issued a controversial publication:<ref>{{Cite web |title=Sutherland Institute | Vouchers Vows & Vexations |url=http://www.sutherlandinstitute.org/uploads/vouchersvows.pdf |url-status=dead |archive-url=https://web.archive.org/web/20110728075042/http://www.sutherlandinstitute.org/uploads/vouchersvows.pdf |archive-date=July 28, 2011 |access-date=August 11, 2011 |df=mdy-all}}</ref> Voucher, Vows, & Vexations.<ref>{{Cite web |date=September 18, 2007 |title=Voucher foe in 'lion's den'? |url=http://deseretnews.com/article/1,5143,695210997,00.html |url-status=dead |archive-url=https://web.archive.org/web/20150402175450/http://www.deseretnews.com/article/1,5143,695210997,00.html |archive-date=April 2, 2015 |access-date=August 11, 2011 |publisher=Deseretnews.com}}</ref> Sutherland called the publication an important review of the history of education in Utah, while critics just called it revisionist history.<ref>{{Cite web |title=The Sutherland Institute |url=http://www.sutherlandinstitute.org/news/news_details.asp?c=1&id=274 |url-status=dead |archive-url=https://web.archive.org/web/20071217202856/http://www.sutherlandinstitute.org/news/news_details.asp?c=1&id=274 |archive-date=December 17, 2007}}</ref> Sutherland then released a companion article in a law journal<ref>{{Cite web |title=Removing Classrooms from the Battlefield: Liberty, Paternalism, and the Redemptive Promise of Educational Choice, 2008 BYU Law Review 377 |url=http://www.sutherlandinstitute.org/uploads/lawreview2008witte.pdf |url-status=dead |archive-url=https://web.archive.org/web/20090325045207/http://www.sutherlandinstitute.org/uploads/lawreview2008witte.pdf |archive-date=March 25, 2009 |access-date=August 11, 2011 |df=mdy-all}}</ref> as part of an academic conference about school choice.<ref>{{Cite web |title=BYU Law Review | Brigham Young University Law Review | Brigham Young University Law School |url=https://digitalcommons.law.byu.edu/lawreview/ |url-status=dead |archive-url=https://web.archive.org/web/20110719155328/http://lawreview.byu.edu/archives/2008_2.htm |archive-date=July 19, 2011 |website=digitalcommons.law.byu.edu}}</ref> [[EdChoice]], founded by Milton and Rose Friedman in 1996, is a non-profit organization that promotes universal school vouchers and other forms of school choice. In defense of vouchers, it cites empirical research showing that students who were randomly assigned to receive vouchers had higher academic outcomes than students who applied for vouchers but lost a random lottery and did not receive them; and that vouchers improve academic outcomes at public schools, reduce racial segregation, deliver better services to special education students, and do not drain money from public schools.<ref>{{Cite web |title=Forster, Greg. (2007) Monopoly Versus Markets |url=http://www.friedmanfoundation.org/friedman/downloadFile.do?id=255 |access-date=August 11, 2011 |publisher=Friedmanfoundation.org}}</ref> EdChoice also argues that education funding should belong to children, not a specific school type or building.<ref name=":6">{{Cite news |date=2017-07-27 |title=Arguments For and Against School Choice in 2017 |language=en-US |work=EdChoice |url=https://www.edchoice.org/blog/arguments-for-and-against-school-choice-2017/ |url-status=dead |access-date=2018-04-25 |archive-url=https://web.archive.org/web/20180425183601/https://www.edchoice.org/blog/arguments-for-and-against-school-choice-2017/ |archive-date=April 25, 2018}}</ref> Their purpose for the argument is to try to argue that people should prioritize a student's education and their opportunity over making a specific type of school better. They also emphasize that if a family chooses a public school, the funds also go to that school.<ref name=":6" /> This would mean that it would also benefit those who value the public education system. ====Legal challenges==== The school voucher question in the United States also received a considerable amount of judicial review in the early 2000s. A program launched in the city of [[Cleveland, Ohio|Cleveland]] in 1995 and authorized by the state of [[Ohio]] was challenged in court on the grounds that it violated both the federal constitutional principle of separation of church and state and the guarantee of religious liberty in the [[Ohio Constitution]]. These claims were rejected by the [[Ohio Supreme Court]], but the federal claims were upheld by [[United States District Court for the Northern District of Ohio|the local federal district court]] and by the [[United States Court of Appeals for the Sixth Circuit|Sixth Circuit appeals court]].<ref>{{Cite web |title=Legal Summary of U.S. Supreme Court decision in Zelman v. Simmons-Harris, 436 U.S. |url=http://edreform.com/school_choice/supreme_court_ruling.htm |url-status=dead |archive-url=https://web.archive.org/web/20060417233028/http://edreform.com/school_choice/supreme_court_ruling.htm |archive-date=April 17, 2006 |access-date=April 21, 2006 |df=mdy-all}}</ref> The fact that nearly all of the families using vouchers attended Catholic schools in the Cleveland area was cited in the decisions.<ref>{{Cite news |last=Friden |first=Terry |date=July 27, 2002 |title=Supreme Court affirms school voucher program |work=CNN |url=http://archives.cnn.com/2002/LAW/06/27/scotus.school.vouchers/ |url-status=dead |access-date=April 21, 2006 |archive-url=https://web.archive.org/web/20060427160627/http://archives.cnn.com/2002/LAW/06/27/scotus.school.vouchers/ |archive-date=April 27, 2006}}</ref> This was later reversed in 2002 in a landmark case before the [[Supreme Court of the United States|US Supreme Court]], ''[[Zelman v. Simmons-Harris]]'', in which the divided court, in a 5β4 decision, ruled the Ohio school voucher plan constitutional and removed any constitutional barriers to similar voucher plans in the future, with conservative justices [[Anthony Kennedy]], [[Sandra Day O'Connor]], [[William Rehnquist]], [[Antonin Scalia]], and [[Clarence Thomas]] in the majority. [[Chief Justice of the United States|Chief Justice]] [[William Rehnquist]], writing for the majority, stated that "The incidental advancement of a religious mission, or the perceived endorsement of a religious message, is reasonably attributable to the individual aid recipients, not the government, whose role ends with the disbursement of benefits." The Supreme Court ruled that the Ohio program did not violate the [[Establishment Clause]], because it passed a five-part test developed by the Court in this case, titled the Private Choice Test. Dissenting opinions included Justice Stevens's, who wrote "...the voluntary character of the private choice to prefer a parochial education over an education in the public school system seems to me quite irrelevant to the question whether the government's choice to pay for religious indoctrination is constitutionally permissible" and Justice Souter's, whose opinion questioned how the Court could keep ''[[Everson v. Board of Education]]'' on as precedent and decide this case in the way they did, feeling it was contradictory. In 2006, the Florida Supreme Court struck down legislation known as the [[Florida Opportunity Scholarship Program]] (OSP), which would have implemented a system of school vouchers in Florida.<ref>{{Cite web |title=Court Throws Out Florida School Voucher Program |url=https://www.npr.org/templates/story/story.php?storyId=5159138 |access-date=April 21, 2006 |website=[[NPR]]}}</ref> The court ruled that the OSP violated article IX, section 1(a) of the Florida Constitution: "Adequate provision shall be made by law for a uniform, efficient, safe, secure, and high-quality system of free public schools."<ref>{{Cite web |title=Florida Supreme Court Official Opinion: SC04-2323 β John Ellis "Jeb" Bush, Etc., Et Al. v. Ruth D. Holmes, Et Al. |url=http://www.floridasupremecourt.org/decisions/2006/sc04-2323.pdf |access-date=November 1, 2006}}</ref> This decision was criticized by Clark Neily, [[Institute for Justice]] senior attorney and legal counsel to Pensacola families using Florida Opportunity Scholarships, as "educational policymaking".<ref>{{Cite web |title=United States Court of Appeals, Twelfth Circuit |url=http://www.trolp.org/main_pgs/issues/v10n2/Neily.pdf |url-status=dead |archive-url=https://web.archive.org/web/20110728130452/http://www.trolp.org/main_pgs/issues/v10n2/Neily.pdf |archive-date=July 28, 2011 |access-date=August 11, 2011 |df=mdy-all}}</ref> ====Political support==== Political support for school vouchers in the United States is mixed. On the left/right spectrum, conservatives are more likely to support vouchers. Some state legislatures have enacted voucher laws. In [[New Mexico]], then-Republican [[Gary Johnson]] made school voucher provision the major issue of his second term as [[Governor of New Mexico|governor]].<ref>{{Cite web |last=Clowes |first=George A. |date=October 1, 2000 |title=Better Education Does Make All the Difference: Governor Gary E. Johnson |url=http://www.heartland.org/schoolreform-news.org/Article/10881/Better_Education_Does_Make_All_the_Difference_Governor_Gary_E_Johnson.html |url-status=dead |archive-url=https://web.archive.org/web/20110527080840/http://www.heartland.org/schoolreform-news.org/Article/10881/Better_Education_Does_Make_All_the_Difference_Governor_Gary_E_Johnson.html |archive-date=May 27, 2011 |access-date=November 14, 2010 |website=School Reform News |publisher=[[The Heartland Institute]]}}</ref> The federal government provided a voucher program for 7,500 residents of [[Washington, D.C.]], called the [[D.C. Opportunity Scholarship Program]].<ref>{{Cite web |title=Washington Scholarship Fund |url=http://www.washingtonscholarshipfund.org/index.html |url-status=dead |archive-url=https://web.archive.org/web/20120121010107/http://www.washingtonscholarshipfund.org/index.html |archive-date=January 21, 2012 |access-date=August 11, 2011 |publisher=Washington Scholarship Fund}}</ref> The program operated until in early March 2009, when congressional Democrats moved to close down the program and remove children from their voucher-funded school places at the end of the 2009/10 school year under the $410 billion [[Omnibus Appropriations Act of 2009]]<ref>Under Title IV of H.R.1015</ref> which, as of March 7 had passed the House and was pending in the Senate. The Obama administration stated<ref>{{Cite news |date=March 4, 2009 |title=Secretary Duncan wants D.C. kids to keep vouchers |work=USA Today |url=https://www.usatoday.com/news/education/2009-03-04-duncan-vouchers_N.htm |access-date=August 11, 2011}}</ref> that it preferred to allow children already enrolled in the program to finish their schooling while closing the program to new entrants. However, its preference on this matter was not strong enough to prevent the president from signing the bill.<ref>{{Cite web |date=March 2, 2009 |title=Briefing by White House Press Secretary Robert Gibbs, 3/2/09 | The White House |url=https://obamawhitehouse.archives.gov/the_press_office/Briefing-by-White-House-Press-Secretary-Robert-Gibbs-3/2/09/ |access-date=August 11, 2011 |website=[[whitehouse.gov]] |via=[[NARA|National Archives]] |df=mdy-all}}</ref> Whether or not the public generally supports vouchers is debatable. Majorities seem to favor improving existing schools over providing vouchers, yet as many as 40% of those surveyed admit that they do not know enough to form an opinion or do not understand the system of school vouchers.<ref>{{Cite web |title=Red Flags on Education: Lack of Knowledge About Vouchers |url=http://www.publicagenda.org/citizen/issueguides/education/publicview/redflags |url-status=dead |archive-url=https://web.archive.org/web/20081227052407/http://www.publicagenda.org/citizen/issueguides/education/publicview/redflags |archive-date=December 27, 2008 |access-date=July 25, 2008 |website=Public Agenda Online}}</ref> In November 2000, a voucher system proposed by [[Tim Draper]] was placed on the [[California]] ballot as Proposition 38. It was unusual among school voucher proposals in that it required neither [[accreditation]] on the part of schools accepting vouchers, nor proof of need on the part of families applying for them; neither did it have any requirement that schools accept vouchers as payment-in-full, nor any other provision to guarantee a reduction in the real cost of private school tuition. The measure was defeated by a final percentage tally of 70.6 to 29.4. A statewide universal school voucher system providing a maximum tuition subsidy of $3,000 was passed in Utah in 2007, but 62% of voters repealed it in a statewide referendum before it took effect.<ref>{{Cite web |title=Vouchers Killed |url=http://www.deseretnews.com/article/1,5143,695225580,00.html |url-status=dead |archive-url=https://web.archive.org/web/20071109045128/http://deseretnews.com/article/1,5143,695225580,00.html |archive-date=November 9, 2007 |access-date=November 3, 2007 |website=[[Deseret News]]}}</ref> On April 27, 2011, [[Indiana]] passed a statewide voucher program, the largest in the U.S. It offers up to $4,500 to students with household incomes under $41,000, and lesser benefits to households with higher incomes. The vouchers can be used to fund a variety of education options outside the public school system.<ref>{{Cite web |date=April 27, 2011 |title=Gov's Education Reform Passes |url=http://www.wishtv.com/dpp/news/politics/state_politics/keys-to-govs-education-reform-pass |url-status=dead |archive-url=https://web.archive.org/web/20120130022452/http://www.wishtv.com/dpp/news/politics/state_politics/keys-to-govs-education-reform-pass |archive-date=January 30, 2012 |access-date=April 28, 2011 |publisher=WISHTV News |df=mdy-all}}</ref> In March 2013, the [[Indiana Supreme Court]] found that the program does not violate the state constitution.<ref>{{Cite news |date=March 26, 2013 |title=Indiana court upholds broadest school voucher program |publisher=Associated Press |url=https://www.foxnews.com/politics/indiana-court-upholds-broadest-school-voucher-program/ |access-date=March 26, 2013}}</ref> In 2025, [[Wyoming]] Governor [[Mark Gordon]] signed the Steamboat Legacy Scholarship Act into law which provides $7,000 vouchers to students.<ref> https://www.wyoleg.gov/Legislation/2025/HB0199</ref> ==== Trump's 2018 Budget ==== President [[Donald Trump]] proposed a 2018 budget that included $250 million for voucher initiatives, state-funded programs that pay for students to go to private school.<ref name=":42">{{Cite magazine |title=Here's Why Researchers Say Betsy DeVos' Proposed School Voucher Program Won't Work |url=https://time.com/4832923/betsy-devos-trump-administration-school-choice-vouchers/ |magazine=Time |language=en |access-date=2018-04-22}}</ref> This 2018 budget served the purpose of "Expanding school choice, ensuring more children have an equal opportunity to receive a great education, maintaining strong support for the Nation's most vulnerable students, simplifying funding for post-secondary education, continuing to build evidence around educational innovation, and eliminating or reducing Department programs consistent with the limited Federal role in education."<ref name=":32">{{Cite web|url=https://www2.ed.gov/about/overview/budget/budget18/budget-factsheet.pdf|title=FACT SHEET: President Trump's FY 2018 Budget}}</ref> The Budget reduced more than 30 programs that duplicated other programs; that were deemed ineffective; or that were more appropriately supported with state, local, or private funds.<ref name=":32" /> Another $1 billion was set aside for encouraging schools to adopt school choice-friendly policies.<ref name=":42" /> [[File:Secretary_of_Education_Betsy_DeVos_at_CPAC_2017_Feb_23rd_2017_by_Michael_Vadon_21.jpg|thumb|Former U.S. Secretary of Education Betsy DeVos]] [[Betsy DeVos]], Trump's education secretary from 2017 to 2021, is also an advocate for voucher programs and has argued that they would lead to better educational outcomes for students.<ref name=":42" /> Both Trump and DeVos proposed cutting the Education Department's budget by about $3.6 billion and spend more than $1 billion on private school vouchers and other school choice plans.<ref>{{Cite news |last1=Strauss |first1=Valerie |last2=Douglas-Gabriel |first2=Danielle |last3=Balingit |first3=Moriah |date=2018-02-13 |title=DeVos seeks cuts from Education Department to support school choice |language=en-US |newspaper=Washington Post |url=https://www.washingtonpost.com/news/education/wp/2018/02/12/devos-seeks-massive-cuts-from-education-department-to-support-school-choice/ |access-date=2018-04-22 |issn=0190-8286}}</ref> Regarding the purpose and importance of the budget, DeVos claimed: <blockquote>This budget makes an historic investment in America's students. President Trump is committed to ensuring the Department focuses on returning decision-making power back to the States, where it belongs, and on giving parents more control over their child's education. By refocusing the Department's funding priorities on supporting students, we can usher in a new era of creativity and ingenuity and lay a new foundation for American greatness. β Betsy DeVos, U.S. [[Secretary of Education]]<ref name=":32" /></blockquote> ====Teaching creationism instead of evolution==== Some private religious schools in voucher programs teach [[creationism]] instead of the [[Evolution|theory of evolution]], including religious schools that teach religious theology side by side with or in place of science.<ref name=politico/> Over 300 schools in the U.S. have been documented as teaching creationism and receiving taxpayer money.<ref>{{Cite web |title=Hundreds of Voucher Schools Teach Creationism in Science Classes {{!}} Blog {{!}} Independent Lens {{!}} PBS |url=https://www.pbs.org/independentlens/blog/hundreds-of-voucher-schools-teach-creationism-in-science-classes/ |access-date=2022-10-14 |website=Independent Lens |language=en-US}}</ref> A strict definition of state-funded religious education was narrowly deemed constitutional in ''[[Zelman v. Simmons-Harris]]'' (2002).<ref>{{Cite news |last=Kopplin |first=Zack |date=January 16, 2013 |title=Creationism spreading in schools, thanks to vouchers |work=MSNBC |url=http://tv.msnbc.com/2013/01/16/creationism-spreading-in-schools-thanks-to-vouchers/}}</ref> At least 35 states have passed various [[Blaine Amendment]]s restricting or prohibiting public funding of religious education.<ref>{{Cite web |last=Denniston |first=Lyle |author-link=Lyle Denniston |date=January 19, 2016 |title=Constitution Check: Are the states' "Blaine Amendments" on shaky ground? |url=http://blog.constitutioncenter.org/2016/01/constitution-check-are-the-states-blaine-amendments-on-shaky-ground/ |url-status=dead |archive-url=https://web.archive.org/web/20160816043553/http://blog.constitutioncenter.org/2016/01/constitution-check-are-the-states-blaine-amendments-on-shaky-ground/ |archive-date=August 16, 2016 |access-date=August 11, 2016 |website=constitutioncenter.org |publisher=[[National Constitution Center]]}}</ref> However, ''[[Espinoza v. Montana Department of Revenue]]'' (2020) ruled that it is unconstitutional to disqualify all religious schools from receiving public funds that other private schools are eligible to get.
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