Parental Rights to End at the School Door?

In a recent article of the Fairfax (VA) Times [1], a school board candidate wrote,

“some members of the School Board argued the school’s duty in loco parentis – to stand in the parent’s place – essentially means that parents’ rights over their children end at the school door. No parent in Fairfax County would agree.”
You probably wouldn’t agree, either. Unfortunately, the Ninth U.S. Circuit Court of Appeals already has. In its 2005 case Fields v. Palmdale [2], the court held that the parents’ fundamental right 

“does not exist beyond the threshold of the school door.”
In Palmdale, the issue was a graphic sex-ed curriculum. In Fairfax, it was interrogating students without notifying parents. But whatever the issue,

“once parents make the choice as to which school their children will attend, their fundamental right to control the education of their children is, at the least, substantially diminished. (Fields v. Palmdale)
This should not be the case. Please act now to reverse this assault by big government courts against parental rights.

Then, pass this on! Every parent of a public school student needs to know the extent to which the courts have robbed them of their rights. Add the message to your Facebook page, or use the button to add it to any social network.

Every child has the right to be raised and represented by parents who love them, and not by disconnected government bureaucrats. Help us to preserve that right today!

A Dangerous Path

Has America Abandoned Parental Rights?

by Michael P. Farris, J.D.reprinted from The Home School Court Report (vol. XXII, no. 4)

I litigated the case that history may judge to be a turning point in parents’ rights. Mozert v. Hawkins County Public Schools(1987) was touted by the media as the “Scopes II” trial. Not only was Mozert tried in Tennessee, but it involved evolution, religion, and a cloud of media onlookers. Attorney Timothy Dyk, now a federal judge appointed by Bill Clinton, was hired by People for the American Way to defend the school district. Beverly LaHaye’s Concerned Women for America employed me as their general counsel to represent the parents whose children had been expelled from the Hawkins County Public Schools.

Why were these children expelled? They refused to read a series of reading books that violated their religious beliefs.

The purpose of the lawsuit was to seek to restore the right of these students to attend public school and be given an alternative reading assignment.

The central issue in the case was: Do parents and children who have sincere religious objections to public school curriculum have the right to alternative instruction for the objectionable material?

The answer given by the Sixth Circuit Court of Appeals was clear: Parents have no such right. Once a child has been submitted to the public schools for his education, parents lose all ability to control the course of instruction.

The Mozert case was so widely publicized that it merited two full-page editorials in USA Today. It was on the front page of nearly every major paper in America at some point. It was covered by all national networks. Yet the Supreme Court of the United States did not think the legal issues in Mozert merited its attention, so the petition for review by the Court was denied. The denial of review was reported on the front page of the Washington Post and widely covered elsewhere.

At the time, I thought that the decision in this case represented a growing trend of anti-Christian bias in the federal courts. So many other decisions had been made allowing public school students to opt out of religiously objectionable material that the only way to explain the disparity seemed to be bias against conservative Christians.

For instance, the Eighth Circuit Court of Appeals had considered a case in 1980 involving public school instruction and announced the general principle, “Forcing any person to participate in an activity that offends his religious or non-religious beliefs will generally contravene the Free Exercise Clause.”1

Additionally, the Sixth Circuit (the same court that decided Mozert) had previously decided another case involving religious beliefs and public school curriculum. In Spence v. Bailey (1972), the court held that it was a violation of the Free Exercise Clause to force a student with conscientious objections to war to attend Reserve Officers’ Training Corps (ROTC) as a condition of attending the public schools. It was constitutionally unacceptable, the court ruled, to force a student to engage in “training contrary to his religious beliefs, or to give up his public education.”

But eventually I realized that what Mozert actually represented was a growing trend of anti-parent bias in the federal courts.

The Mozert court held that there was no “burden” on religious freedom or parents’ rights when the schools forced children to read religiously offensive books as a condition of attending public schools.

Understanding the burden test is very important.

In First Amendment and related cases (including parental rights cases), according to the current Supreme Court, there are a series of questions that are supposed to be answered in the proper order. Think of the process like a series of hurdles. If a parent fails to clear the first hurdle in the case, the case ends right there.

The first hurdle is the “burden” test. This test is essentially designed to answer the question: Are the plaintiffs’ rights even arguably violated? A claim can be considered so remote or insubstantial that it fails on this threshold issue. If your rights are not “burdened,” your case is over immediately without any need to consider the remaining hurdles.

If a parent does clear the “burden hurdle” there remains the compelling interest test—which is a balancing test designed to determine how important your rights are in this situation compared to the importance of the government’s goals and purposes. But if the parent does not clear that initial barrier of demonstrating that his rights are arguably violated, the court never reaches the balancing test.

The implication of failing to clear this first hurdle signals that the government’s power is essentially absolute in the particular area. If the court holds that a parent’s rights are not burdened when a public school forces a child into a sex education course without the parent’s permission, this establishes a very broad rule. It means that no matter how egregious the sex education program may be, parents’ rights are not implicated at all. The court will only balance the importance of the particular program against the parents’ claims of right after the parents have proven that their rights have been burdened.

Thus, if a court says that parents’ rights are not burdened when the public schools force children to take instruction that is contrary to their religious faith, that is a categorical ruling. It does not matter whether the public school’s program is tangential or central to the curriculum. It does not make a difference if the religious objections are numerous or few. It certainly does not matter if the parents believe that the school has invaded their religious convictions as opposed to their religious preference. If there is no burden on parents’ rights or religious freedom when the schools force children to learn secular material that violates the parents’ faith, this ruling is absolute for all parents of all faiths.

This background helps place an incredibly alarming decision made in 2005 by the Ninth Circuit Court of Appeals in its proper context.

In 2001, the Palmdale School District in California decided to give a survey to students in its elementary schools. Included in this psychological survey were a number of sex-related questions. These included inquiries into touching one’s private parts and thinking about doing so with others, among other fairly explicit questions.

Parents were outraged that this survey was conducted without a proper disclosure to the parents. But the court’s decision did not rest upon the district’s previous superficial disclosure to parents.

The Ninth Circuit held:

Although the parents are legitimately concerned with the subject of sexuality, there is no constitutional reason to distinguish that concern from any of the countless moral, religious, or philosophical objections that parents might have to other decisions of the School District—whether those objections regard information concerning guns, violence, the military, gay marriage, racial equality, slavery, the dissection of animals, or the teaching of scientifically-validated theories of the origins of life. Schools cannot be expected to accommodate the personal, moral or religious concerns of every parent. Such an obligation would not only contravene the educational mission of the public schools, but also would be impossible to satisfy.

The court went on to make it entirely explicit that once children are left at the public school’s front door, all parental control over the child’s education ceases.

In sum, we affirm that the Meyer-Pierce3 right does not extend beyond the threshold of the school door. The parents’ asserted right “to control the upbringing of their children by introducing them to matters of and relating to sex in accordance with their personal and religious values and beliefs,” by which they mean the right to limit what public schools or other state actors may tell their children regarding sexual matters, is not encompassed within the Meyer-Pierce right to control their children’s upbringing and education.

The Ninth Circuit has a reputation for being the most liberal in the nation. In this instance, it simply sided with the vast majority of recent federal court decisions.

The First Circuit Court of Appeals made a similar outlandish ruling in Brown v. Hot, Sexy and Safer Productions, Inc. (1995). This case involved a mandatory, school-wide assembly that contained offensive and suggestive sexual material. The First Circuit said that while parents have the right to choose alternative forms of schooling, they have no constitutional right to direct their child’s education inside the public school. Consider how broadly the First Circuit characterized these rights:

The first instance involves the state proscribing parents from educating their children, while the second involves parents prescribing what the state shall teach their children.

The court did not use the term prescribe correctly in this case. Parents were not prescribing what the public schools had to teach their children. They were seeking to proscribe the kind of instruction they wanted left out of their children’s public school education: they just wanted to opt out of sexually explicit material.

So, if we correct the use of this term, what the First Circuit said was this: Parents cannot be told by the state to stop teaching their children, but parents cannot stop the state from teaching those children just because the parents do not like what is being taught. None of the cases just described were decided with a balancing test. Every case held that parents’ rights had not been burdened or implicated at all. In fact, according to the courts, parents’ rights to control the education of their children completely stop at the schoolhouse door.

What is the implication for homeschoolers?

First, we should be very glad that we have decided to homeschool our children. If any parents still believe that they have a constitutional right to direct their children’s education inside a public school, these cases demonstrate that such a view is a fantasy. It should not be this way. Parents of public school students should be able to decide to remove their children from sex surveys and assemblies, but according to the federal courts, they have no such right.

Second, saying that the state can force children to learn explicit sex education material if they are enrolled in public schools is a short step from saying that the state can force all children to receive such instruction. If we do not take alarm when other parents’ rights are treated so badly, we should not be surprised when our own rights are invaded. Note in particular the wording used by the First Circuit: “Parents may not prescribe what the state may teach their children.” Although the context of this case was in a public school, the actual wording used is a very broad claim of state power over the minds of all children.

In fact, the 2002 decision of a Texas federal district court in Barrow v. Greenville Independent School District shows how close these cases come to invading the freedom of homeschoolers. In Barrow, a public school teacher sought a promotion to the rank of assistant principal. She was denied this promotion solely because her children were enrolled in a Christian school. The federal court held that neither her religious freedom nor her parental rights were at stake. Public employees who are denied promotion because they refuse to participate in government education for their own children are being given a choice of losing a job or losing a constitutional right to control the education of their children.

This case suggests that we are on a very dangerous path.

Unless parents’ rights are treated on a par with other fundamental rights, the government will continue to demand more and more authority over our children. It is time to put parents’ rights into the text of the United States Constitution.

1Florey v. Sioux Falls School Dist., 49-5, 619 F.2d 1311 (8th Cir. 1980).
2Fields v. Palmdale School Dist., 427 F.3d 1197 (9th Cir. 2005).
3In two significant cases, Meyer v. Nebraska, 262 U.S. 390 (1923), and Pierce v. Society of Sisters, 268 U.S. 510 (1925), the U.S. Supreme Court recognized that the Due Process Clause does protect the right of parents to control the upbringing of their children.

Examples of Concern

  • We can all agree that our schools should be places of refuge and safety for children–and that schools should work alongside parents and respect their desire to protect, not only children’s physical wellbeing, but also their emotional and psychological development. Schools should respect parents’ desire to safeguard their children’s innocence.

  • But despite this reality—and the fact that the U.S. Supreme Court has generally recognized parents’ constitutional rights to direct the upbringing and education of their children— this protection has not been affirmed in recent lower court cases that specifically address what happens in the classroom. There continues to be a dangerous trend of parental rights being eroded in our nation’s public school system.

Examples of this trend include:

  • Parents in a small Washington State community who expressed concern that a principal gave their fifth-grade children an explicit lesson detailing different kinds of sexual practices. “I didn’t appreciate them teaching my daughter—who is innocent of that—at all,” one parent told a reporter. “Basically, how I feel is, it’s just the same as raping somebody, but you’re raping their innocence instead of their physical being.”

  • Parents in Alameda, California, were told they could not opt their elementary-age children out of mandatory lessons promoting homosexuality and gay marriage, even if it violated their families’ most deeply held religious beliefs or they just didn’t think their child was psychologically or emotionally prepared for the topic.

  • Parents are discovering that explicit or invasive surveys have been given to children without their knowledge or permission. Read about the controversial sexual survey given to students in D.C. schools.

  • Meanwhile, lower courts have issued disturbing rulings that have weakened parents’ rights to give consent for these surveys. For instance, in a case involving a survey that included questions about “thinking about having sex” and “thinking about touching other people’s private parts,” the Ninth Circuit Court of Appeals ruled that a parent’s right to determine whether such themes are appropriate “does not extend beyond the threshold of the school door.”

  • In Massachusetts, one parent even went to jail after refusing to leave school premises until educators promised to notify him before teaching his children about homosexuality. He never got that promise, even after a long court battle.

  • Whether it’s books promoting alternate forms of relationships and marriage to kindergartners, crossword puzzles introducing third graders to the idea of changing one’s sex, or graphic instruction about how to engage in homosexual behavior for middle school age kids—parents across the country have encountered disturbing incidents of radical advocacy and sexual experimentation being promoted in their child’s school, and against the will of the parents.

  • In recent years, there has been an unprecedented increase in these incidents across the country, and the growth of aggressive, nationwide advocacy movements to push the boundaries even more.


  • At Focus on the Family, we believe that children are a cherished gift from the Lord—and that parents are the ones primarily responsible for guiding and preparing them for a life of service to God and to humanity.
  • Parents have a God-ordained right and responsibility to determine what is best for their children.
  • In the majority of cases, parents and legal guardians are the ones who are closest emotionally, mentally and spiritually to their children and the most in tune with their needs. Given their intimate knowledge of their children, they should have the protected ability to direct and give guidance concerning their children’s educational experience.
  • This includes the ability to determine when, how and if their children are introduced to controversial sexual topics–as well as other educational philosophies that may conflict with families’ deeply held Judeo-Christian values and principles.
  • Protecting parents’ rights in education also protects a self-governing society by safeguarding against an intrusive government school system that can eventually infringe on religious freedoms.
  • We also recognize that these rights have limits, and we would never condone the abuse of any child—whether verbal, physical, sexual or emotional—or parental neglect.
  • We believe these principles are rooted in legal history, social science data and Judeo-Christian traditions.

Judeo-Christian Tradition

Scriptures such as these remind us of parents’ spiritual responsibility to guide and protect their children:
  • Proverbs 22:6 says, “Train up a child in the way he should go; even when he is old he will not depart from it.”
  • Psalm 127:3 proclaims, “Behold, children are a heritage from the Lord, the fruit of a womb a reward.”
  • Malachi 2:15 asks, “Has not the Lord made them [a husband and wife] one? In flesh and spirit they are His. And why one? Because He was seeking godly offspring.”

Legal History

  • The U.S. Supreme Court affirmed the “liberty of parents and guardians to direct the upbringing and education of children under their control” (Pierce v. Society of Sisters, 1925).
  • The Court declared that a child is not “the mere creature of the State; those who nurture him and direct his destiny have the right, coupled with high duty, to recognize and prepare him for additional obligations” (Pierce v. Society).
  • It also recognized that “choices about marriage, family life, and the upbringing of children are among associational rights this Court has ranked as ‘of basic importance in our society’ ” (M.L.B. v. S.J.J. , 1996).
  • The high court stated: “The history and culture of Western civilization reflect a strong tradition of parental concern for the nurture and upbringing of their children. This primary role of the parents in the upbringing of their children is now established beyond debate as an enduring American tradition” (Wisconsin v. Yoder, 1972).

Social Science Data

Research has shown that parents are one of the most influential factors in a child’s academic success.  Just to list a few examples:
  • According to a synthesis of research on parental involvement conducted over nearly a decade, “Many studies found that students with involved parents, no matter what their income or background, were more likely to:
    • earn higher grades and test scores, and enroll in higher-level programs
    • be promoted, pass their classes, and earn credits
    • attend school regularly
    • have better social skills, show improved behavior, and adapt well to school
    • graduate and go on to postsecondary education.”
  • A  U.S. Department of Education report also stated that, “Three decades of research provide convincing evidence that parents are an important influence in helping their children achieve high academic standards. When schools collaborate with parents to help their children learn and when parents participate in school activities and decision-making about their children’s education, children achieve at higher levels.  In short, when parents are involved in education, children do better in school and schools improve.”
  • According to Heritage Foundation researchers, “Children with involved parents have higher academic achievement. Not only do students score higher on tests but they are more prepared to start school and have a greater likelihood of graduating.”
  • Clearly, the data demonstrates that parents have a strong reason and right to be involved in their children’s education.


  • These increasing encroachments demonstrate why it’s so important to remain vigilant in protecting parents’ rights and responsibilities to be the primary educators and guardians of their children. That’s why we remain dedicated to speaking up for the protection of their rights in public schools.
  • What You Can Do: Visit our Take Action page and send your local school officials and/or elected officials a model parental right policy developed by national legal experts that strengthens these rights in schools.

"There is no fundamental right of parents to be the exclusive provider of information regarding sexual matters to their children, either independent of their right to direct the upbringing and education of their children or encompassed by it. We also hold that parents have no due process or privacy right to override the determinations of public schools as to the information to which their children will be exposed while enrolled as students."— Fields v. Palmdale School District PSD, Ninth Circuit Court of Appeals (2005)
Do parents have a right to control the upbringing of their children, especially when it comes to what their children should be exposed to in terms of sexual practices and intimate relationships?
That question goes to the heart of the battle being played out in school districts and courts across America right now over parental rights and whether parents essentially forfeit those rights when they send their children to a public school. On one side of the debate are those who believe, as the U.S. Supreme Court has ruled, that "the child is not the mere creature of the state" and that the right of parents to make decisions concerning the care, custody and control of their children is a fundamental liberty interest protected by the U.S. Constitution. On the other side are government officials who not only believe, as the Ninth Circuit Court of Appeals ruled in Fields v. Palmdale School District PSD (2005), that "[s]chools cannot be expected to accommodate the personal, moral or religious concerns of every parent," but go so far as to insist that parents' rights do "not extend beyond the threshold of the school door."
A recent incident in Fitchburg, Massachusetts clearly illustrates this growing tension over whether young people, especially those in the public schools, are essentially wards of the state, to do with as government officials deem appropriate, in defiance of the children's constitutional rights and those of their parents. On two separate occasions this year, students at Memorial Middle School (MMS) in Fitchburg were administered surveys at school asking overtly intimate and sexually suggestive questions without their parents' knowledge or consent.
Students were required to complete the Youth Risk Behavior Survey (YRBS) at school, a survey which asks questions such as "Have you ever tried to kill yourself?", "Have you ever sniffed glue, or breathed the contents of spray cans, or inhaled any paints?", and "With how many people have you had sexual intercourse?" Older students were also given the Youth Program Survey (YPS), which asks true/false questions about a student's beliefs about contraception ("I feel comfortable talking with any partner I have about using a condom") and sexual activity ("I have had oral sex at some point in my life").
While the survey questions are explicit enough in terms of their content, the multiple-choice answers are actually quite informative—at least, in the sense that they educate young test-takers about a host of practices and terms with which they might not actually be familiar and provide them with suggestions on how to go about acquiring drugs, sex, etc. This is a not-so-subtle form of indoctrination into behaviors that no parent would want for their children. For example, the survey asks: "During your life, how many times have you used heroin (also called smack, junk, or China White)? ...how many times have you used methamphetamines (also called speed, crystal, crank, or ice)? ... how many times have you used ecstasy (also called MDMA)?" And for those not up on the various prescription drugs, the survey provides a handy list: "During your life, how many times have you taken a prescription drug (such as OxyContin, Percocet, Vicodin, codeine, Adderall, Ritalin, or Xanax) without a doctor's prescription?"
One question asking how students acquired cigarettes suggested the following as responses:
A. I did not smoke cigarettes during the past 30 days

B. I bought them in a store such as a convenience store, supermarket, discount store, or gas station 

C. I bought them from a vending machine 

D. I gave someone else money to buy them for me 

E. I borrowed (or bummed) them from someone else 

F. A person 18 years old or older gave them to me 

G. I took them from a store or family member 

H. I got them some other way
As for sex, the survey asks, "The last time you had sexual intercourse, what one method did you or your partner use to prevent pregnancy?" The responses provided are an education in themselves.
A. I have never had sexual intercourse

B. No method was used to prevent pregnancy 

C. Birth control pills 

D. Condoms 

E. Depo-Provera (or any injectable birth control), Nuva Ring (or any birth control ring), Implanon (or any implant), or any IUD 

F. Withdrawal 

G. Some other method 

H. Not sure
Moreover, instead of acquiring written consent from parents, which is required under federal law,  before subjecting students to these invasive surveys, MMS officials relied on so-called "passive consent," by which parents are presumed to have given their approval if they do not return the opt-out form sent home with students. When challenged by a parent over this passive consent practice, a representative with the local social services agency administering the survey stated that the reason the "passive consent" system was adopted and why the method of obtaining consent would not be changed is that the agency needs a 98% participation rate in the survey in order to qualify for future government grants. In other words, recognizing that the participation rate would be 30% or less if a system requiring actual written parental consent were employed, test administrators adopt the fiction that a failure to respond is tantamount to parental consent in order to achieve the numbers needed to qualify for grant funding for their activities.
Unfortunately, Fitchburg, Mass., is not the only locality using young people as test subjects for the purpose of mining data and securing government funding. In fact, as of 2009, the only states that did not participate at all in the survey were Oregon, Washington and Minnesota. The national Centers for Disease Control and Prevention (CDC), the government agency responsible for creating and distributing the survey, states that the main purpose of the survey is to monitor "priority health-risk behaviors and the prevalence of obesity and asthma among youth and young adults."
Currently used in at least 45 states, the YRBS test takes approximately 35 minutes to complete, with questions on everything from how much television the student watches to thoughts on suicide, sexual activity and drug use. For example, the 2011 middle school questionnaire includes such questions as: "Have you ever seriously thought about killing yourself?" "Have you ever made a plan about killing yourself?" "Have you ever used marijuana?" "Have you ever used any form of cocaine, including powder, crack, or freebase?" "Have you ever had sexual intercourse?" "The last time you had sexual intercourse, did you or your partner use a condom?" "Have you ever sniffed glue, or breathed the contents of spray cans, or inhaled any paints or sprays to get high?" "Have you ever taken any diet pills, powders, or liquids without a doctor's advice to lose weight or to keep from gaining weight?" "Have you ever vomited or taken laxatives to lose weight or to keep from gaining weight?"
Developed in 1990 by the CDC, the Youth Risk Behavior Surveillance System is similar to other mental health screening programs that have been creeping into the classroom since President George W. Bush's New Freedom Commission on Mental Health recommended mental health screenings for all school-aged children, including those in preschool. However, while the supposed goal is to identify and prevent risky behavior among young people, many parents are understandably up in arms over these tests.
First, there are concerns about how the tests are administered. Health screening tests like YRBS are often given to students without parental knowledge or consent. While the CDC insists that local parental permission procedures are followed prior to administering the test, many school systems use the passive parental notification procedures, which assume that parents have given their consent unless they notify the school of an objection. But passive notification is merely a surreptitious way to avoid obtaining written parental consent. And in the end, whether due to the child losing the notification form or forgetting to give it to the parents, parents are often left in the dark, unaware that their children are being subjected to such invasive tests.
Second, the manner in which these tests are administered puts them in violation of the Protection of Pupil Rights Amendment (PPRA), a federal law that was intended to protect the rights of parents and students. PPRA, which covers educational entities that receive federal funds, applies whenever students are asked to submit to any survey, analysis or evaluation that seeks private information about the student, such as political affiliations, sexual activity, illegal activities or religious beliefs. The PPRA allows parents to inspect their children's instructional materials and requires that schools obtain "written parental consent" before schools engage in such programs as mental health screening.
Third, critics of these risk assessment tests insist that they're aimed at advocating antidepressant drugs for teenagers. For example, TeenScreen, which is similar to YRBS in its intent to identify suicidal tendencies and social disorders, has been labeled by the Alliance for Human Research Protection as a "duo-drug promotion scam" that declares "otherwise normal children to be mentally ill." As a result, an increasing number of children are being medicated with antidepressants, despite FDA warnings about the increased risk of suicidal thinking and behavior in children who take them. All the while, pharmaceutical companies rake in the profits.
Finally, legitimate questions remain about whether such tests really help students achieve healthier lifestyles. TeenScreen, for example, has an 84% false-positive rate. This means that 84% of teens diagnosed as having some sort of mental health or social disorder are, in fact, perfectly normal teenagers. Furthermore, although the CDC insists that there is no danger in asking students highly suggestive questions about sex, drugs and suicide, most parents prefer to decide the timing and content of such a sensitive discussion.
Helping America's teens make positive, healthy and responsible lifestyle choices is a worthy goal, but it must start with parents within the home. If the schools are to be part of the process, they must ensure that parents are fully informed and involved at every step of the way. In turn, parents should demand that they be notified about mental health evaluations and that the evaluations not be given unless they have provided express written permission, which is required under federal law. Parents should also be provided an advance copy of the screening questionnaire in order to make an informed decision about whether they want their child to be screened.
As Elliott M. Davis, writing for the Harvard Journal of Law & Public Policy, concludes in his analysis of the Ninth Circuit'sFields decision:
The right of a parent to control the upbringing of his child is fundamental. Though public schools can and do usurp many parental choices, this right—which encompasses "the inculcation of moral standards"—vests first in parents. When a child passes through the public school doors, he does not become a "mere creature of the state." Judicial interference in public schools should be minimal because legislatures are primarily charged with crafting policy; courts, however, should not stand idly by as public schools violate fundamental rights. As the Supreme Court declared in West Virginia State Board of Education v. Barnette, "The Fourteenth Amendment, as now applied to the States, protects the citizen against the State itself and all of its creatures—Boards of Education not excepted." Although the public school exerts a high level of control over its students, its control is not absolute. American constitutional jurisprudence affirms that this society is not one where children are wholly disconnected from their parents and educated entirely by the state. If the Meyer-Pierce parental right is to have any real meaning, it is to preclude the public school from egregiously usurping the parental role in matters of the utmost importance.

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