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This article is part of our “Children and Education Rights” series.
If you’d like to check out other articles in this series, click here.

Earlier this year, Harvard Magazine, the university’s alumni publication, interviewed Elizabeth Bartholet, professor at Harvard Law School and faculty director of its Child Advocacy Program, for an article titled “The Risks of Homeschooling.” In the article, Bartholet argued that unregulated homeschooling poses a danger to children, exposing them to risk of educational deprivation and even child abuse. Conservative media immediately criticized Bartholet, arguing that homeschooling constitutes a superior educational method to public education and accusing Bartholet of elitism and ignorance. 

But perhaps no part of Bartholet’s article garnered more anger among conservatives than her statement that compulsory education is not only about “giving children the knowledge to eventually get jobs and support themselves” but also about exposing them “to community values, social values, democratic values, ideas about nondiscrimination and tolerance of other people’s viewpoints.” Secretary of State Mike Pompeo tweeted in response to Bartholet’s article, arguing that: “The risk to children is NOT from homeschooling. The risk is from radical leftist scholars seeking to impose THEIR values on OUR children.” Pompeo’s response to Bartholet represents part of a deep, enduring disagreement over the meaning and purpose of education in America.

The political battles over education that we see today have their roots in a fundamental question: What is education? In the mid-1800s, the nation’s first public schools — originally known as “common schools” — sought to bring together different children in an effort to teach tolerance and create a common culture. In the mid- to late twentieth century, as public schools began to expose children to a wider variety of subjects and ideas, evangelical Christians — previously among the most ardent supporters of public schools — objected, arguing that parents should have the right to prevent their children from coming into contact with materials they deemed contrary to their religious beliefs. Most recently, and most related to Bartholet’s critique, Christian homeschool advocates have used homeschooling to “shelter” children from objectionable ideas or people in order to create ideological purity, in a wholesale rejection of Mann’s vision of bringing children into contact with other children of different backgrounds and beliefs. Is teaching democratic values such as tolerance part of the purpose of education, as Mann would have it? Or is the purpose of education to instill in the child the religious or political beliefs of the parent, as Christian homeschool advocates argue? In either case, education is about far more than simply teaching academics.

After tracing the development of these contrasting ideas about education in America, we will finish our journey by looking at the U.N. Convention on the Rights of the Child, a human rights treaty written in 1989 and signed by every country in the world — except the United States. As I conclude, I will argue that the framework within which education is discussed should move away from whether children belong to their parents or to the state, and toward an understanding of children as independent entities with their own rights. 

Schools as Social Agents

Throughout our nation’s history, public education has always been about more than teaching reading or mathematics. America’s public schools were born out of concerns about democracy and the maintenance of a free society. Early education reformers questioned whether a democratic system of government could survive without an educated public. 

Horace Mann (1796-1859), considered to be the father of public schools, believed that a “common school” would help create a common culture out of an increasingly diverse and varied populace. Mann argued that the survival of a democratic form of government could be ensured only through bringing children into contact with other children who were different from them. In 1837, Mann gave up his position as the president of the Massachusetts senate to become the first secretary of his state’s newly founded board of education, where he set up the nation’s first statewide system of common schools. Other states followed suit, and by 1918, every state had its own system of public schools. 

Horace Mann Daguerreotype by Southworth & Hawes. Wikimedia Commons.

Mann set out to create schools that were nonsectarian and thus universally acceptable. Mann’s common schools began with prayer and Bible reading. However, when the Bible was read aloud, it was read without commentary; no teacher would tell students that the Baptist, or Anglican, or Seventh Day Adventist interpretation of a given passage was correct. At a time when most nations still had established churches and existing schools were frequently parochial, Mann’s system of nonsectarian schools was new and radical. 

Prior to the development of common schools, most schools were run by churches or religious benevolent societies. As states and jurisdictions began publicly funding common schools in the early and mid-1880s, religious groups sought access to this money. In 1831, the Catholic Benevolent Society sought a portion of New York City’s common school funding on the basis that they were educating children. After considering the request, the city responded that: “If religion be taught in a school it strips it of one of the characteristics of a Common School…. No school can be common unless parents of all religious sects, Mohammedans and Jews, as well as Christians, can send their children to it, to receive the benefits of an education without doing violence to their religious belief.” The trouble was that common schools, for all that they were nonsectarian, tended to be vaguely Protestant. Even reading the Bible aloud without comment was a Protestant practice. In an 1840 speech against common schools, Catholic Bishop John Hughes declared that “parents or guardians of Catholic children cannot allow them to frequent such schools without doing violence” to their rights of conscience.

The Dutch Calvinist immigrants who settled in Michigan and the upper midwest and founded the Christian Reformed Church during the mid- to late 1800s objected to Mann’s vision for another reason. In the late 1800s, these Calvinists were heavily influenced by Abraham Kuyper, a Dutch theologian and politician in the Netherlands who argued that all education was based on underlying presuppositions. “There is no neutral education that is not governed by a spirit of its own, and the very spirit of the religiously neutral school is the antithesis of all positive belief,” Kuyper insisted. In the Netherlands, Kuyper fought to create an educational system in which education funds followed the pupil to the school of the parent’s choice, rather than being used to fund a system of public schools. The influence of Kuyper’s ideas is still visible today: Secretary of Education Betsy DeVos, a fierce proponent of charter schools and vouchers, grew up in the Christian Reformed Church in Michigan and attended Calvin College, where she was heavily influenced by studying Kuyper’s writings.

While every state barred the provision of public funding to parochial schools by the end of the 1800s, the state of Oregon went farther in 1922, passing a law that required all children to attend public schools and effectively banning private schooling. William Guthrie, attorney for the Society of Sisters in the Holy Names of Jesus and Mary, argued before the Supreme Court that: “The child of a foreigner is quite as likely to be assimilated and Americanized in a private or parochial school as in a public school.” Public schools, Guthrie continued, were not the only schools capable of adequately preparing children to participate in American society: “The private and parochial schools teach the same subjects as the public schools — whatever one does to inculcate and foster patriotism, the other can and does do quite as well.”

In Pierce v. Society of Sisters (1925), the Court sided with Guthrie, striking down the Oregon statute. However, the Court did not question the state’s right to regulate private schools, or to set standards and requirements for these schools: 

“No question is raised concerning the power of the State reasonably to regulate all schools, to inspect, supervise and examine them, their teachers and pupils; to require that all children of proper age attend some school, that teachers shall be of good moral character and patriotic disposition, that certain studies plainly essential to good citizenship must be taught, and that nothing be taught which is manifestly inimical to the public welfare.”

Mann had envisioned a system of common schools that would bring all children together and create a common culture based on shared values like democracy. The Court’s finding in Pierce closed the door on a fundamental aspect of Mann’s vision: public schools would never bring all children together. However, the Court also affirmed Mann’s premise: that education should and did play a role in shaping and preparing the citizenry of a democracy. 

Evangelicals and Secular Humanism

If Mann was the father of public schools, John Dewey (1859–1952), who taught at Columbia University from 1904 to 1930, was the father of modern education. Dewey’s theory of education centered on learning by doing. Dewey promoted a hands-on, experienced-based approach to education. Rather than a teacher standing at the front of the room delivering information for children to memorize and regurgitate, Dewey envisioned a classroom where children were provided with information and encouraged to experiment and arrive at solutions themselves, often working in groups. Dewey argued that teaching children how to be flexible thinkers was critical for the survival of our democracy in a fast-paced modern world: 

There will be almost a revolution in school education when study and learning are treated not as acquisition of what others know but as development of capital to be invested in eager alertness in observing and judging the conditions under which one lives. Yet until this happens, we shall be ill-prepared to deal with a world whose outstanding trait is change.

While public schools remained far more committed to rote learning than Dewey preferred, his ideas about education proved as enduring as Mann’s. Dewey’s ideas about education would ultimately upset evangelical Christians, who believed that children should not be taught how to think, as Dewey envisioned, but what to believe.

In the 1940s and 1950s, the Dutch Calvinist idea that all education was based on an underlying set of presuppositions made its way into evangelical seminaries and denominations. Evangelical theologians who had previously been supporters of the nation’s public schools changed their minds, arguing that schools in which God was present only in morning devotionals must implicitly communicate to children that religion is peripheral and unimportant. Some pointed to Dewey’s belief that traditional religion was backwards and destined to die out as proof that public schools had become antithetical to religion. These theologians began to call for the founding of evangelical private schools. 

Most evangelical laypeople, however, were unconvinced. Evangelicals had long been firmly committed to the project of public schools — and opposed to private schooling. While public schools had shifted from an emphasis on moralistic teaching to a greater focus on academics in response to the nation’s changing economic needs, they retained their earlier Protestant ethos in the form of morning exercises such as prayer and Bible reading. This was enough for evangelical laypeople to feel that public schools reflected their culture and their values. Perhaps for this reason, evangelical theologians’ calls for Christian day schools went largely unrealized; only a small number of such schools were founded in the 1940s and 1950s. 

John Dewey at the University of Chicago in 1902. Wikimedia Commons.

The Engel v. Vitale (1962) and Abington v. Schempp (1963) decisions, which barred Bible reading and teacher-led prayer from public schools, hit evangelical laypeople like a thunderclap. Lawyers for the families who brought the suits argued that the official nature of these devotionals placed too much pressure on dissenting children to conform, but most evangelicals felt that allowing these children to opt out of the devotionals had been sufficient. School desegregation, reminiscent of Mann’s idea that educating different children together would create a common culture and cure national division, was similarly earth-shaking. “They put the Negroes in the schools and now they’ve driven God out,” Alabama Congressman George Andrews declared. A robust Christian school movement sprang up in the late 1960s, with thousands more Christian day schools founded in the 1970s and 1980s.

Evangelicals had been comfortable in the nation’s public schools as long as they believed their culture and their values set the norms. Now, they began to fear that it was their children who were being assimilated — and into an America they no longer recognized. 

By the late 1960s, evangelicals desperately wanted a way to understand the turbulence they were seeing, as the civil rights movement, second wave feminism, sexual libertinism, and protests against the Vietnam War shook the nation. Francis Schaeffer, whose ideas about secularism were heavily influenced by Kuyper protege Cornelius Van Til, offered evangelicals the explanation they were waiting for. For Schaeffer, all of the changes of the 1960s were a product of secular humanism — the idea that man, and not God, determines truth. Schaeffer defined secular humanism as “the system whereby men and women, beginning absolutely by themselves, try rationally to build out from themselves, having only Man as their integration point, to find all knowledge, meaning and value.” Dewey, with his emphasis on teaching children to think independently, featured prominently in Schaeffer’s critique of American education. Schaeffer was wildly successful in popularizing his views; in the 1970s, his film series, How Should We Then Live, was screened in evangelical churches across the country. 

Schaeffer inspired a veritable cottage industry of evangelical writing tying secular humanism not only to the turbulence of the 1960s but also to every condition they believed was plaguing the nation, from gay rights to communism. Evangelical pastor Tim LaHaye, later author of the popular Left Behind books, wrote in The Battle for the Mind (1980) and The Battle for the Public Schools (1983) that secular humanism had turned the nation’s public schools into factories for indoctrinating children into atheism. In 1983, these ideas prompted Tennessee housewife Vicki Frost to ask for her children to be exempted from reading class at their local public school. She had read her children’s reading textbooks, she said, and was concerned by some of the stories in them, including stories that referenced sorcery and mind control. “I would rather my children have an F than be taught demonology,” she told the school board. Frost and her fellow plaintiffs argued before the district court that “after reading the entire Holt series, a child might adopt the views of a feminist, a humanist, a pacifist, an anti-Christian, a vegetarian, or an advocate of a ‘one-world government’.” Therefore, they said, “they must not allow their children to be exposed to the Holt series.” 

In Mozert v. Hawkins County, the 6th circuit ruled against Frost and her fellow plaintiffs on the grounds that “the students are not required to affirm or deny a belief or engage or refrain from engaging in a practice prohibited or required by their religion” and that the idea that the series “could” or “might” lead the students “to come to conclusions that were contrary to the teachings of their or their parents’ religion” was “not sufficient to establish an unconstitutional burden.” Frost wanted to prevent her children from having access to materials she felt contained information that might undermine their religious beliefs; however, the 6th circuit found that her children merely being exposed to information did not violate her rights. 

Tim LaHaye, The Battle for the Public Schools, Old Tappan, New Jersey, Fleming H. Revell Company, 1983.

Around the same time Frost objected to her children’s readers, a group of parents in Mobile County, Alabama, argued that the readers in use in their school district promoted “the religions of secularism, humanism, evolution, materialism, agnosticism, atheism and others.” In Smith v. Board of School Commissioners, decided in 1987, the same year as Mozert, the 11th circuit found that “the message conveyed [in the textbooks] is one of a government attempt to instill in Alabama public school children such values as independent thought, tolerance of diverse views, self-respect, maturity, self-reliance and logical decision-making” and that this was “an entirely appropriate secular effect.” 

Frost wanted to ensure that her children would grow up to adopt her religious views by controlling the information they were exposed to; the parents in Mobile County perceived materials designed to teach tolerance and independent thought as inimical to their religious beliefs, and wanted to prevent their children from being exposed to these materials.

In arguing that teaching children critical thinking and tolerance of diverse views had a neutral and reasonable effect, the 11th circuit upheld both Dewey and Mann’s views of education. While educators would not teach children what to believe — that would violate the idea of the common school — they would expose them to other points of view and teach them how to think for themselves. But evangelicals, who believed in absolute truth, objected to teaching children how to think without teaching them what to believe

Greenhouses and the Joshua Generation

After spending eighteen months embedded as a researcher in a Christian day school in Illinois, education professor Alan Peshkin concluded his 1986 book, God’s Choice, by writing that these schools presented a paradox for pluralism. “Espousing pluralism is not functional to the cause of their monolithic Truth,” he explained. “Thus, while Supreme Court judgments secure their right to exist, their own doctrine does not move them to protect and preserve that network of ideas and practices which supports these judgements.” In other words, while the school Peshkin observed benefited from pluralism — the idea that a diversity of opinions can coexist harmoniously — it failed to teach its own students to value pluralism. 

“I never heard a discussion, let alone an elaboration, of the concept of pluralism and its implications for their own survival as a group,” Peshkin wrote. “On the other hand, I did hear Roman Catholics maligned, Mormons lumped together with Hare Krishnas and practitioners of Transcendental Meditation, and daily reinforcements of the scriptural Truth supporting these positions.” Peshkin argued that we must accept this paradox, but that care must be taken, because such schools could in the future present a threat to an open society. 

Homeschooling raises similar questions about pluralism. When a child is homeschooled, their parents have complete control over which adults and which children they come in contact with — as well as what ideas they are exposed to. Many parents who homeschool do expose their children to a variety of peers and work to engage their children fully in their communities. Some children who are homeschooled may come in contact with a greater diversity of people than they would have in the public school they were zoned to attend. At the same time, however, many evangelical Christian parents homeschool explicitly as a means of preventing their children from having contact with people and ideas that are not in line with their beliefs. 

Evangelical Christians frequently use a greenhouse metaphor to describe their reasons for homeschooling. “The greenhouse allows the gardener to control all the elements of the environment so that the plant grows into a sturdy, mature plant with deep, well anchored roots, and a strong supportive trunk,” wrote one Christian home educator. “Then the gardener makes the final transplant… by the time they complete the high school years they are finally anchored in GOD’S WORD, and have learned to stand against the world.” 

Greenhouses are not only about keeping things in, however. They are also — or perhaps primarily — about keeping things out. Gregg Harris, an author and speaker prominent in Christian homeschooling circles in the 1980s and 1990s, wrote about his decision to carefully screen the children his children were allowed to have contact with as follows: “What would happen if our children were allowed to run around unsupervised with… other children? The companion of fools would suffer harm… The more our children have the opportunity to be the companions of foolish children, the more impervious they are to our counsel.”

Michael Farris, an early homeschool leader and conservative activist — and Vickie Frost’s lawyer in the Mozert case — has combined this idea of a greenhouse with his political ambitions. In his 2005 book The Joshua Generation, Farris wrote that “the homeschooling movement will succeed when our children, the Joshua Generation, engage wholeheartedly in the battle to take the land.” In 2000, Farris founded Patrick Henry College, enrolling mostly graduates of Christian homeschooling. While he insists he is not advocating a “political coup,” journalist Kathryn Joyce wrote in her 2007 book, God’s Harvard, that the school “bills itself as a pipeline to official Republican Washington,” and that Farris routinely worked his connections in Washington to place his students as interns. Farris located his college in Virginia, just outside of D.C. — the nation’s center of power. In April 2020, the school’s website boasted that at least ten current White House staffers are Patrick Henry College graduates. 

Farris is no marginal figure. In 1983, he founded the Home School Legal Defense Association, an organization that continues to fight any oversight of homeschooling to the present day. Farris proved a master at media manipulation in the 1990s, deftly propelling himself to prominence. In 2017, Farris became president of the Alliance Defending Freedom, a well-connected evangelical legal advocacy and training group that funds and trains lawyers to oppose marriage equality, abortion access, and transgender rights. Even after this move, Farris remains perhaps the best-known name in the Christian homeschooling world. 

In the early 2000s, I sat in a lecture hall at Patrick Henry College and looked on as Farris spoke to a room full of homeschooled high school students. His vision, he said, gesturing across the room, was for the students sitting in this section to be in the Senate, and for the students sitting in that section to be in the House. The students in the front row, he said, would be on the Supreme Court. For Farris, homeschooling is a means of preparing a generation of young people to realize his vision of what our nation should look like. 

What About Children’s Rights?

Today, many states place few or no requirements on either private schools or homeschooling. The 1980s saw a “race to the bottom” as states created minimalistic homeschool statutes and stripped state education bodies of the ability to set requirements for private schools. The public should understand that there is a tradeoff in this. Education has never been merely about imparting academic skills. For better or for worse, education has always also been about more: about imparting tolerance, as it was for Mann, or about teaching critical thinking, as it was for Dewey. Or, as it is for Farris, a means of forming children in a particular image and political persuasion. The word “education,” tied as it is in the public mind to academic skills, too often lets us gloss over everything else that takes place in the school — or outside of it. 

When Levi Whisner, pastor of God’s Tabernacle in Bradford, Ohio, founded a Christian day school in his church, he argued that he did not need to meet the state’s requirements for private schools because these requirements embodied the philosophy of secular humanism and violated his free exercise of religion. In State v. Whisner, decided in 1976, the Ohio Supreme Court found in favor of Whisner. Requiring “a non-public religious school to cooperate with elements of the community in which it exists,” the court found, “infringes on the rights of these appellants, consistent with their religious beliefs, to engage in complete, or nearly complete, separation from community affairs.” 

The idea that a family can choose to separate their child from the community and raise them in isolation, subject to no educational requirements whatsoever, flies in the face of the U.N. Convention on the Rights of the Child. According to the Convention, the child has the right to an education that develops their talents “to their fullest potential” and prepares them “for responsible life in a free society, in the spirit of understanding, peace, tolerance, equality of sexes, and friendship among all peoples, ethnic, national and religious groups and persons of indigenous origin.” In stark contrast to the greenhouse metaphor, which involves “sheltering” a child by denying them access to information that conflicts with the beliefs of their parents, the Convention also states that children have “the right to freedom of expression” and that this right includes “freedom to seek, receive and impart information and ideas of all kinds.” 

The United States is the only country in the world that has not signed the Convention, in part due to opposition from Farris and other conservatives. However, the idea that children have a right to access information — and the right to receive an education that teaches tolerance and equality — is predominantly held among all other countries in the world. 

The Whisner case in Ohio relied heavily on Wisconsin v. Yoder, a 1972 Supreme Court case that found that Amish parents could not be compelled to send their children to high school. In Yoder, Amish parents argued that high school attendance was contrary to their religious beliefs and to the Amish way of life. The Court found in favor of the parents, relying heavily on the fact that the Amish had their own independent communities in which an eighth grade education was sufficient for community membership and success. 

 The word “education,” tied as it is in the public mind to academic skills, too often lets us gloss over everything else that takes place in the school — or outside of it. 

Proponents of homeschooling draw on Yoder to justify their argument that states should not intervene to ensure that homeschooled children have access to an education that is adequate, by any definition, in the same way that they point to the Court’s finding in Pierce that parents have the right “to direct the upbringing and education” of their children. However, Pierce also found that states had the right (and even the responsibility) to set standards for private schools. Similarly, in Yoder, the Court found that the state could, if it chose, set standards for the vocational education Amish children received. Neither decision grants parents the right to opt out of all restrictions or requirements, or prevents states from setting standards designed to protect the child’s right to an education, in all that that entails. 

When Pompeo responded to Bartholet’s statement that education should involve exposing children “to community values, social values, democratic values, ideas about nondiscrimination and tolerance of other people’s viewpoints” by claiming that the true threat is “from radical leftist scholars seeking to impose THEIR values on OUR children,” his words reflected a view of education more in line with that of Frost or Farris than Mann or Dewey. Education, in this view, is about insulating children from alternative ideas and ensuring ideological purity and a replication of the parents’ beliefs in the mind of the child. But where does this leave the child’s right to an education that prepares them to live in understanding and tolerance with all peoples, or the child’s right to seek and receive information and ideas?

While the U.S. has not signed the U.N. Convention on the Rights of the Child, the idea that children have rights independent from those of their parents is not radical. In Pierce, the Supreme Court found that children were not “mere creatures of the state.” The corollary, however, is that children are also not mere possessions of their parents. ♦

Dr. Rachel Coleman has been the executive director of the Coalition for Responsible Home Education, a national child advocacy nonprofit that focuses on homeschooled children, since 2014. Dr. Coleman earned her Ph.D. in U.S. history from Indiana University, with a focus on the history of children, childhood, and the family.

Recommended Citation

Coleman, Rachel. “From Common Schools to Greenhouses: School Battles, Homeschooling, and Children’s Rights.” Canopy Forum, December, 2020.