Parental Rights and Public Education

Parental rights advocates believe parents should have authority to determine what, when, where, and how information is taught to children in schools. School rights advocates argue that education cannot be tailored to meet all parent’s individual instructions and goals. State governments are responsible for ensuring that the educational needs of children are met, but in recent years, the federal government has become influential in shaping school standards. Many lawsuits involving parental rights in public schools have been decided by American courts. The complexity of the issue poses a continual challenge for families, schools districts, and the nation's legal system.

Keywords Advocate; Curriculum; Due Process; First Amendment; Fourteenth Amendment; Parent Rights; Psychotropic drugs; Referendum; Right; School Rights

Education & the Law > Parental Rights & Public Education

Overview

The American public school system is responsible for creating safe learning environments in which children can expand their knowledge and skills. In 2021, 49.5 million students attended public schools each day, each coming from a variety of religious, cultural, educational, and economic backgrounds. Most adults agree on the importance of providing children with quality instruction designed to produce well-informed, contributing members of society. However, establishing consensus on what knowledge is, how knowledge should be communicated, and who is entitled to receive knowledge has been debated in the United States for centuries.

Parental rights advocates insist that the authority to determine educational parameters should lie in the hands of parents, citing amendments in the United States Constitution and twentieth century Supreme Court rulings. School rights advocates contend that the uniqueness of the American public school environment necessitates that such power be reserved for teachers and school administrators.

Historical Perspective

Since Horace Mann created the nation's first public school system in Massachusetts in the 1800s, American society has undergone significant changes. Americans have witnessed realities of war, immigration, and an expanding global economy. They have seen advances in transportation, technology, and communication. They have challenged attitudes on religion, sexuality, and politics. Changes in the ways people live, work, and think have affected American communities, businesses, governments, and families. They have also affected the American public school system.

Supreme Court Cases

The United States Constitution does not directly address the concept of public schooling, so each state is responsible for establishing an educational system for its citizens and resolving education-related problems. Yet, on several occasions, disagreements about parental rights in schools have demanded federal intervention—Do parents have the power to dictate which learning materials are presented to students? Can parents refuse to send children to public schools? Should parents be required to send children to public schools for a set number of years? These questions have ultimately been addressed by the United States Supreme Court. Three prominent cases present examples of Federal intervention in resolving parental rights issues:

Meyer v. State of Nebraska

Following World War I, a school district in Nebraska was sued after a teacher offered German language instruction to students at Zion Parochial School. Nebraska law prohibited the teaching of foreign languages in public and private schools, and the Nebraska Supreme Court ruled in favor of the state. The case was appealed to the United States Supreme Court, and in Meyer v. State of Nebraska (1923), the lower court's ruling was overturned. The Court ruled that forbidding schools to teach languages other than English violated citizens' due process protections guaranteed by the Fourteenth Amendment (Meyer v. State of Nebraska, 1923). In the decision written by Associate Justice James Clark McReynolds, the Court showed support for parental rights in schools by emphasizing parents' constitutional liberties "to marry, to establish a home and bring up children" (Meyer v. State of Nebraska, 1923, para. 10).

Pierce v. Society of Sisters

In 1922, voters in the state of Oregon passed a referendum requiring all children in the state between the ages of 8 and 16 to attend public schools. Two private schools, the Hill Military Academy and the Society of Sisters of the Holy Names of Jesus and Mary, sued the state. They claimed that their First Amendment and Fourteenth Amendment rights had been violated. An Oregon District Court ruled in favor of the referendum, and the ruling was appealed to the United States Supreme Court. In Pierce v. Society of Sisters (1925), the Supreme Court ruled in favor of private schools, stating that the Oregon referendum interfered "with the liberty of parents and guardians to direct the upbringing and education of children" (Pierce v. Society of Sisters, 1925, para. 10). According to the Court, parents must comply with compulsory attendance laws, but they maintain the right to choose between public and private school options (Russo, 2005).

Wisconsin v. Yoder

In the early 1970s, an Amish community in the state of Wisconsin refused to send their children to school after the students had graduated from the eighth grade. Wisconsin law required all students to attend school until age sixteen. The Amish viewed the state's law as a direct threat to their religion and cultural way of life. In Wisconsin v. Yoder, the Supreme Court ruled in favor of Amish parents, declaring that the state's compulsory attendance law conflicted with protections afforded by the First Amendment (Wisconsin v. Yoder, 1972). In the opinion of the Court, "a state's interest in universal education…is not totally free from a balancing process when it impinges on fundamental rights…and the traditional interest of parents with respect to the religious upbringing of their children…." (Wisconsin v. Yoder, 1972, para. 11).

The Parental Rights & Responsibilities Act

Reading, writing, math, and science remained the core of curriculum in most public schools throughout the twentieth century but changing needs of society led to changes in classrooms, too. Schools added courses in health education, sexuality, and cultural diversity. They began requiring immunizations as prerequisites for enrollment. They created student questionnaires on topics like suicide attempts, preferred sexual orientation, and typical home environments. Schools viewed the changes in curriculum, medical requirements, and surveys as vital to their educational missions.

Some parents became concerned with the increasing influence and power schools had assumed. In 1993, the Parental Rights and Responsibilities Act (PRRA), was sent to Congress as legislation to limit government's involvement in children's lives, especially within the boundaries of the public school system. The bill found sponsors in twenty-eight states (Billitteri, 1996), and its advocates claimed the legislation was needed to empower parents against the established educational bureaucracy (Billitteri, 1996).

Professional and governmental organizations, such as the National Education Association and the American Civil Liberties Union, opposed PRRA. Affording greater legal power to parents, the groups argued, would undermine the nation's public education system, lead to exorbitant legal bills incurred fighting parent-instigated court battles, and result in a lessening of child-protection standards in schools (Billitteri, 1996). Passage of the bill, they warned, would limit schools' abilities to teach sex education courses, select library books, and offer pregnancy and drug counseling to teenagers (Billitteri, 1996). The Parental Rights and Responsibilities Act failed to pass.

Yet, the impetus that initiated PRRA did not dissipate with the bill's failure to become law. In a nationwide telephone survey conducted by International Communications Research in 1999, 52 percent of adults felt that schools had strayed too far from teaching the basic subject materials ("Americans willing," 1999). Many respondents wanted expanded legal control over curriculum, discipline, and values that their children were exposed to in public schools. Some parents argued it was not the job of teachers to offer curriculum instruction on subjects such as homosexuality or contraception. Others did not want schools to dictate what medications children should be required to take. A few believed school-sponsored questionnaires were too intrusive on children's privacy.

No Child Left Behind Act of 2001

In 2001, Congress passed federal legislation, called the No Child Left Behind Act (NCLB), designed to connect federal funding with measurable improvements in public school standards. Among other things, the law required:

• Each public-school teacher be certified or licensed and demonstrate mastery of relevant subject matter;

• Each student be tested in math and reading (and later science) in grades 3-8 and at least once in high school; and that

• Parents be allowed to enroll children in an alternative school if their assigned one was identified as needing improvement ("Four Pillars," 2001).

Some parental rights advocates viewed NCLB as a positive step to ensuring parents' abilities to provide quality education to children. They believed public schools would be more accountable to taxpayers and that children would benefit from increased educational options (White, n.d.). Other parental rights advocates viewed NCLB as a negative interference by the federal government into local control of schools. They complained that programs and restrictions imposed by NCLB were not adequately funded and that standardized tests (used to measure schools' successes and failures) were unreliable (McKenzie, 2003). Both sides agreed that reforms were needed if NCLB was to continue to shape school goals through federal funding.

In 2012, President Barack Obama began issuing waivers to states that freed them from the requirements of NCLB if they demonstrated that they would raise educational standards and improve accountability. By 2013, thirty-two states and the District of Columbia had been given waivers. When the NCLB was due for reauthorization, Congress described the law as much maligned, loathed, and broken. It was replaced by the Every Student Succeeds Act (ESSA) (Levesque, 2015), which limited the federal government's role in education policy. The ESSA was renewed through 2021 (Walsh et al., 2021).

Ongoing Issues

Attempts to balance parental rights with the needs of schools continue to cause conflicts in America's public school system. The following four issues, in particular, pose significant challenges.

Curriculum

American courts typically rule in favor of schools when parents sue for control of school districts' curriculum choices:

• In California, a federal court ruled that a public school could require seventh-grade students to participate in a course about Islam despite objections from parents ("Time to restore," 2007).

• A judge in Texas ruled that schools do not have to reschedule classes to conform to an individual child's schedule (Simpson, 2003).

• A Connecticut court ruled that parents could not demand that children be excused from mandatory health education lessons (Simpson, 2003).

• A conservative parent group in Tennessee sued a school district because of the curriculum’s discussion of race and gender (Schwartz, 2022).

Sex Education

One of the most challenging curriculum questions debated, however, concerns sex education. A 2003 poll conducted by National Public Radio (NPR), the Kaiser Family Foundation, and Harvard's Kennedy School of Government found that most Americans believed basic courses on sex education should be taught in public schools ("Sex education," 2003), but lacked consensus on exactly what such education should include.

Historically, sex education programs in schools were aimed at preventing teenage pregnancy and sexually transmitted diseases. The 2003 NPR poll discovered, however, that 15 percent of adults wanted schools to limit lessons on sexuality to abstinence without providing information on contraception usage. Forty-six percent believed that teaching abstinence was best but wanted schools to include lessons on contraceptives. Interestingly, respondents' definitions of the word "abstinence" varied widely: some applied it to mean intercourse and oral sex, while others defined it to include kissing and intimate touching. Federal money was made available to schools willing to offer abstinence programs; thirty percent of school principals reported that their schools complied to receive the funds ("Sex education," 2003).

By 2010, under President Barack Obama, the government had begun dedicating federal funding to comprehensive sex education. The administration eliminated funding for two-thirds of abstinence programs and added $190 million for new evidence-based programs. Additional funds for comprehensive and progressive programs were granted throughout 2011 and 2012. Sex education also had a place in the Patient Protection and Affordable Care Act, which included a program (the Personal Responsibility Education Program, or PREP) for personal responsibility to reduce the risk of unintended pregnancy. Among other topics, PREP teaches adolescents about how both abstinence and contraception prevent pregnancy and sexually transmitted infections.

When asked questions pertaining to homosexuality, respondents to the 2003 NPR survey were more decisive. Fifty-two percent at the time agreed schools should acknowledge and define homosexuality, but only 8 percent wanted it deliberately presented as an acceptable lifestyle ("Sex education," 2003). By 2013, nine states required an inclusive discussion of sexual orientation in sex education and American tolerance toward homosexuality had increased, with over 60 percent of people believeing that gay people should be accepted in society.

By 2022, sexual and reproductive health were topics of concern for most Americans, including parents, as Roe v. Wade was overturned. Though most parents supported sex education in middle and high school, the lack of standardized curriculum on the topic remained. Only thirty-nine states mandated the topic be included in school curriculum, and of those, only thirteen required the curriculum to include medically accurate information. In 2018, the Centers for Disease Control recommended twenty topics for schools to include, but less than half of schools met these criteria. More problematic is the misinformation or negative subtext associated with some state's sex education curriculum. In Oklahoma, for example, "it is taught that “homosexual activity” is one cause of contracting HIV/AIDS." Only nine states required sex education be inclusive of LGBTQ individuals, and some states even prohibited the discussion of contraception and sexual orientation. This puts a large percentage of students at a disadvantage concerning sexual health. Parents across the U.S. have opposing viewpoints on the topic, but the data is clear—abstinence-only education does not work and increased information on contraceptive options decreases the teen pregnancy rate (Shah, 2022).

Medical Requirements

Public schools have assumed a greater role in the physical and mental health of students in recent decades, and parental rights advocates have challenged schools' authority to do so.

On-site Healthcare

In the 1990s, the number of school-based medical clinics rose substantially, from about 200 at the beginning of the decade to 1,135 at the end (Green, 2001). The clinics were created to combat rising occurrences of HIV/AIDS, to provide contraceptives, to conduct pregnancy testing, and to offer treatments for sexually transmitted diseases. Parents were often unaware of services and medical referrals provided to students by the clinics (Green, 2001). Bauer notes, for example, a situation in which two sisters in Stephens County, Georgia, (ages 14 and 15) were transported to a birth control clinic by a public school employee without their parent's consent or knowledge. The children received birth control pills, pelvic examinations, and underwent AIDS testing (Bauer, 1997).

Following the COVID-19 pandemic, it became evident that schools are critical to, not only facilitate learning, but to support children's overall well-being, nourishment, and health. In 2022, 3,000 school-based health centers operated in medically underserved neighborhoods around the U.S. Services at these clinics include dental, vision, and hearing services, vaccinations, flu treatment, diabetes care and more. Access to this type of care allows students to be healthy and learn. The Centers for Disease Control and Prevention task force on the matter noted that this type of care is key in advancing health equity in the twenty-first century and allows better educational opportunities. Congress allotted $5 million to school-based health centers in 2021, but this funded only 25 of the 300 applications the program received ("We need more," 2022).

Medications

In 2019, it was estimated that approximately 6 million children from age three to seventeen in the United States had been diagnosed with attention deficit hyperactivity disorder (ADHD) (Centers for Disease Control and Prevention, 2022). To maintain discipline in classrooms and ensure effective learning environments for all students, many schools insisted that students with ADHD take psychotropic drugs to alleviate symptoms prior to attending classes. Some parents believe schools should not have the power to require medications as prerequisites for access to public education but attempts to pass federal legislation aimed at ending the practice have been unsuccessful ("Time to restore," 2007). However, schools are prohibited from requiring students to take any sort of medication under the Individuals with Disabilities Education Act (IDEA).

In the summer of 2006, the Centers for Disease Control and Prevention recommended that all girls be vaccinated against Human Papilloma Virus (HPV) starting at age 12. The immunization prevents a virus that is transmitted through sexual intercourse that can cause cervical cancer. Social conservatives and parental rights advocates across the nation opposed forced immunization. By 2013, there were two HPV vaccines on the market recommended for both girls and boys. By 2021, Hawaii, Rhode Island, Virginia, and D.C. had legislation requiring HPV vaccinations for girls before they enter the sixth grade, but parents can opt out of this requirement based on religious, moral, or medical opposition ("The HPV vaccine," 2021).

Student Surveys

A volunteer mental health counselor at Mesquite Elementary School in San Francisco, California sent a letter to parents informing them that students would be given a survey about early childhood experiences and asking for parental consent. The permission form did not note there would be questions of a sexual nature on the survey. The survey was administered to students at the school, ages seven to ten. In Fields v. Palmdale School Dist. (2005), a circuit court ruled in favor of the school, stating that while parents could determine the forum for a child's education (Davis, 2006), parents did not have exclusive rights to provide sexual information to children and could not dictate public school curriculum (Trotter, 2006).

In C.N. v. Ridgewood Board of Education (2005), a New Jersey circuit court also ruled in favor of schools concerning surveys. Middle and high school students had been given a survey concerning their exposure to alcohol and drug use, sexual activity, and violence (Davis, 2006). The court ruled that school officials had not violated privacy rights of students or parents by administering a voluntary, anonymous survey on personal behaviors and relationships (Russo, 2005).

Dress Codes

Nearly one in four public elementary schools, and one in eight public middle and high schools, in the United States have clothing policies (as cited in Motsinger, 2007), many requiring students to wear uniforms. By 2010, 10 percent of high schools required student uniforms. In Canady v. Bossier Parish School Board (1998), a circuit court ruled that a school had the right to require students to wear uniforms if its policy was designed to promote education and not as censorship on students' freedoms of expression ("Canady v. Bossier Parish School Board," 2001).

Yet, some parents continued to insist that school uniform rules violated First Amendment rights (Mitchell, 2003). Laura and Scott Bell sued the Anderson, Indiana school district over its policy that students wear black, navy or khaki pants or skirts and solid-color shirts with collars. The Bells claimed that in addition to violating their children's constitutional rights of free expression, the school's policy also denied them access to free education since purchasing the special clothing would cost their family more than $600 (Motsinger, 2007).

According to David Hudson, a First Amendment scholar at the First Amendment Center in Nashville, Tennessee, most lawsuits against school uniforms fail because courts view dress codes as a way to promote school learning environments and not as a direct attack on freedoms of expression (as cited in Motsinger, 2007). However, courts sometimes contradict one another in their rulings. The 9th U.S. Circuit Court ruled that a public school could ban a child from wearing an anti-homosexual T-shirt; the 2nd U.S. Circuit Court ruled that a public school could not ban a student from wearing an anti-government one ("Time to restore," 2007).

Dress code issues among public school attendees and their parents continued into the 2020s. Unfortunately, they tended to reflect outdated and sexist stereotypes and those who were punished for violations of the dress code were disproportionately minority students or those who school officials tended to view as deviant. However, dress codes which result in discrimination based on race, gender, religion, or any other characteristic protected under Title IX, Title VI, or the U.S. Constitution are prohibited. This includes protection for transgender or cisgender individuals who wear clothes consistent with their gender identity (Sherwin et al., 2022).

Conclusion

The issue of parental rights in schools continues to challenge those invested in the education of American children. Parental rights advocates believe decisions involving children should be made by parents, and they cite the United States Constitution and past Supreme Court rulings as the legal basis for their position. They want parents to have control over what information is conveyed to children, when and where information is given, and how information is provided. School rights advocates argue that the unique environment of the public school necessitates that authority to determine what is in children's best interests be given to teachers and school administrators. They claim they cannot logistically, or financially, tailor each child's education to parents' individual instructions and goals.

Throughout the past century, United States courts have ruled on issues concerning parental rights in schools. The Supreme Court has ruled in favor of parental rights in cases involving foreign language instruction and compulsory education requirements. Lower courts have typically ruled in favor of schools concerning control over educational curriculum, school medical mandates, student privacy issues, and dress code policies.

Terms & Concepts

Advocate: To favor; to maintain a cause.

Curriculum: Courses offered by a school, or a program of courses mandated at the governmental level and required for study in the public schools.

Due Process: A legal requirement that protects an individual from unfair or unreasonable treatment as a result of enacted laws; formal legal proceedings based on established rules and principles.

First Amendment: "Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble…."

Fourteenth Amendment (Section 1): "…nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws."

Psychotropic Drugs: Medications that act on the mind, usually given to children with ADHD.

Referendum: A legislative measure or proposal submitted for popular vote.

Right: A claim of power, entitlement, or privilege.

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Suggested Reading

Darden, E. C. (2013). Does safety conflict with parental rights? Phi Delta Kappan, 94, 68–69. Retrieved December 11, 2013, from EBSCO Online Database Education Research Complete. http://search.ebscohost.com/login.aspx?direct=true&db=ehh&AN=86877108&site=ehost-live

Holtzman, M. (2013). GLBT parents' rights during custody decision making: The influence of doctrine, statute, and societal factors in the United States. Journal of GLBT Family Studies, 9, 364–392. Retrieved December 11, 2013, from EBSCO Online Database Education Research Complete. http://search.ebscohost.com/login.aspx?direct=true&db=ehh&AN=89026238&site=ehost-live

Maddox, N. T. (2012). Silencing students' cell phones beyond the schoolhouse gate: Do public schools' cell phone confiscation and retention policies violate parents' due process rights? Journal of Law & Education, 41, 261–269. Retrieved November 4, 2014, from EBSCO Online Database Education Research Complete. http://search.ebscohost.com/login.aspx?direct=true&db=ehh&AN=70502455&site=ehost-live

Mitchell, H. W. & Knechtle, J. C. (2003). Uniforms in public schools and the first amendment: A constitutional analysis. Journal of Negro Education, 72, 487. Retrieved August 13, 2007, from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=12941877&site=ehost-live

Peters, S. F. (2003). The Yoder case. University Press of Kansas.

Simpson, M. D. (2002). ESEA extends federal reach in schools. NEA Today 20, 20. Retrieved August 13, 2007, from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=6279213&site=ehost-live

Viteriti, J. P. (1999). Choosing equality: School choice, the constitution, and civil society. Brookings Institution Press.