Combs v. Home-Center School District

540 F.3d 231 (2008)

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Combs v. Home-Center School District

United States Court of Appeals for the Third Circuit
540 F.3d 231 (2008)

CR

Facts

Act 169, a Pennsylvania law, permitted parents to satisfy their children’s mandatory education requirement through a homeschool program overseen by their local public school district. Parents electing to homeschool their children were required to maintain a portfolio of materials used, student work, and results of standardized tests and to submit to an annual evaluation of the child’s work. The school districts’ oversight was limited to ensuring the homeschool program satisfied the act’s requirements regarding hours of instruction, subjects taught, and students’ progress; they did not choose or review the materials parents used, nor challenge the evaluators’ assessments of the programs. The parents of six Christian families (plaintiffs) sued the school districts (defendants), contending that the districts’ mandatory oversight of their homeschool programs under Act 169 violated their rights to the free exercise of religion and to control their children’s education and religious upbringing under the First and Fourteenth Amendments, challenging the act both facially and as applied. The parents moved for summary judgment, which the district court denied. The school districts then moved for summary judgment, which the district court granted, finding that Act 169 was a facially neutral law.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

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