“Homeschooling Around the World: Challenges and Solutions”
Michael P. Donnelly, Esq
Director of International Relations
Adjunct Professor of Government
Patrick Henry College
1 Patrick Henry Circle
Purcellville, VA 20132
It is a privilege to be here with you in Spain - a country that has contributed so much to our world. Indeed, it may not be the best measure, but there has to be something very special about a culture whose language ranks among the top 5 or so spoken in the world. As I flew over and travelled by train from Barcelona I enjoyed the beautiful scenery of the coast. And of course I congratulate you on your well-earned world cup victory. After the US was eliminated by Ghana I was rooting for Spain and I marveled at the elegant style of play of the Spanish team. If I had to name a favorite team outside the United States where I cheer for DC United I would have to pick Real Madrid. But I digress – I am not here to talk about sports with you. Rather I bring you greetings from your fellow homeschoolers in America where the number of students is over 2 million which translates into perhaps 750,000 families. This represents about 3-4% of the school age population. In America, homeschooling is a growing and main stream form of education for children. Today all 50 states have laws, regulations or court decisions that explicitly recognize parent’s rights to homeschool. However, homeschooling in America, like much of the world today has not always been as free and accepted as it is today.
And in the United States compared to many countries we have a relatively higher degree of freedom from government oversight and control – at least in some of our states. As a federal republic the individual states of our country are responsible for their own educational laws. In nearly 20% of the states there is no government oversight whatsoever. In most of the rest the only form of government contact required is simple notification. In just under half of the states is some form of assessment required.
Our association was started in order to defend parents in trouble and to advocate for greater freedom for homeschooling. Since 1983 we have been working in courts of law, in national and state legislatures, in the media, with universities and colleges, government agencies, and at the international level as advocates for home schooling. We were founded on the basic premise, one that was acknowledged by our own supreme court - that is that parents have a fundamental right to direct the education of their children. I believe with my whole heart that families are the fundamental building block of society and that parents have a natural right which must be protected to raise their children according to their convictions. For me this fight is personal – I believe that children are a gift from God who puts children in a family for their good and as blessings to parents. My wife and I homeschool our seven children so I have a personal appreciation of the love you show for your children by accepting the challenges and sacrifices that comes with homeschooling. Of course the benefits far outweigh the costs but we must acknowledge the sacrifices parents make to teach their own children at home – especially the moms since they do the majority of the work in most cases..
It should come as no surprise that parents who seek to homeschool their children are treated with suspicion or even hostility. This happened frequently and was the norm during the early years of homeschooling in America. During the 70s, 80s and even 90s’ parents received similar treatment as homeschoolers in countries like Germany, Sweden, and now apparently Spain. During our fight to legalize homeschooling, American parents were fined, threatened with jail, threatened with the custody of their children, and some cases actually did serve prison sentences for homeschooling the children and lose their children to state custody. These controversies expose the underlying conflict between competing views of the relationship between families and the State in the area of education.
But where does this resistance come from? And why should such difficult obstacles exists if the right of parents to direct their children's education is acknowledged as a fundamental human right? Well first – many people don’t want parents to educate their children, they believe it is the state’s responsibility to do it. And secondly – when you suggest that homeschooling or even just parental freedom to choose the child’s form of education which should include homeschooling – some people look at you like you’re from another planet.
I was in Frankfurt Germany last night where I presented at a Global conference on the philosophy of law and social philosophy. For the first time this conference included homeschooling as a human right – this was my argument. But there are many in government and in the professional educational establishment who believe that it is the State’s role to influence and shape society have no choice but to argue that the State must take a leading role in educating children. After all, children are the future of the society and of the State. Indeed, if the State is responsible for education or has a significant interest therein, then it must have broad authority by which to prescribe the method, mechanism, and acceptable outcomes of education; it must also be able to review and enforce these desired outcomes. This is a dangerous and fairly recent view of education that has had tragic consequence during some of the most troubling periods of the last century. However, if parents, on the other hand, are primarily responsible for a child’s education then it is the State’s duty to defer to parents absent a compelling reason to interfere.
This controversy over freedom in education for parents is particularly reflected in homeschooling where parental influence is at its height - a scary thing to those who are seeking to remake society in a new image. For some every child has not only a right to education but in their opinion they must receive a state-approved and state-funded educational experience. This, they argue, is vital to the transmission of “national values” and to ensure that every child is educated and safeguarded by trained professionals.
Dr. Charles Glenn and Dr. Jan de Groof are education professors at leading universities in the United States and Netherlands. They have written an encyclopedia about education policy in 40 countries. In their books they write that “to deny choice for parents to determine where and how their children are educated is unjust and unworthy of a free society.” Not only is it unjust - it is also contrary to accepted norms of current international human rights doctrine. All of the primary and foundational international human rights documents recognize that the right of parents to control and direct their children’s education is a tenet of human rights doctrine and is not only recognized but is superior in relation to the claims of the State in educating children.
Let’s look at some of these documents:
Article 26, part 3, of The Universal Declaration of Human Rights of 1948 states that “parents have a prior right to choose the kind of education that shall be given to their children” (emphasis added). The fact that the word “prior” is used is indicative of the hierarchy and primacy of the right of parents in relation to the State.
The 1950 European Convention for the Protection of Human Rights and Fundamental Freedoms provides in Article 2 that,
in the exercise of any functions which it assumes in relation to education and teaching, the State shall respect the right of parents to ensure such education and teaching in conformity with their own religious and philosophical convictions.
In 1966, the UN General Assembly opened the International Covenant on Economic, Social and Cultural Rights for signature. The covenant entered into force in 1976. Article 13.3 states:
the States Parties to the present covenant undertake to have respect for the liberty of parents […] to choose for their children schools, other than those established by public authorities, which conform to such minimum educational standards as may be laid down or approved by the State and to ensure that religious or moral education of their children is in conformity with their own convictions.
Even though this covenant allows the State to create certain “minimum educational standards”, it reaffirms the Declaration’s recognition of parents’ rights. That same year, the International Covenant on Civil and Political Rights went into effect, providing in Article 18, paragraph 4 that:
The States Parties to the present Covenant undertake to have respect for the liberty of parents and, when applicable, legal guardians to ensure the religious and moral education of their children in conformity with their own convictions.
Without quibbling over or parsing what it means to “ensure . . . education in conformity with their own convictions,” it seems eminently clear, as a foundational principle, that the right of parents to direct their children’s education is considered a human right that must be respected by States professing an allegiance to the human rights set forth in these documents.
Well if this is true then why is educational freedom not supported by progressives when other human rights, such as the freedoms of speech, the press, religious belief, and voluntary association” are supported? Why do these progressive elites “see family as a source of resistance to social progress and put their trust in government-sponsored schooling to make children more progressive and more enlightened than their parents”? Why are there countries like Germany, Sweden, Brazil, and the Canadian province of Quebec, among others, that claim to respect general human rights norms and yet ban or oppress homeschooling parents? What is it that makes the education of a child is so controversial? Why should there be such a struggle between parents and governments over how, what, when, and where a child learns?
Perhaps Emory University School of Law Professor Martha Albertson-Fineman makes the argument for this point of view best when she writes: "The appropriate suggestion for our current educational dilemma is that public education should be mandatory and universal. Parental interest can supplement but never replace the public institutions where the basic and fundamental lesson should be taught and experienced by all American children which is this - that we must struggle together to define ourselves both as a collective and as individuals.(emphasis added)
Apparently it is not enough that children have the opportunity to experience a state-funded and state-controlled education; homeschooling and private schools must be banned so that all children go to public schools. This view has its roots in the philosophy of Jean Jacques Rousseau a French social contract philosopher who believed that the state must control education. Rousseau, on the other hand, viewed the State as the supreme authority with respect to children. He firmly understood the importance of education and its role in shaping society. It was necessary, he thought, to compel parents to give up their children to receive an education that reflected the enlightenment values of the impending French Revolution. The State, in Rousseau’s world, must control education.
For Rousseau, the State was the stabilizing force in society and thus had to take control of the education of children in order to enable them--and the State--to fulfill their ultimate potential. Revolutionaries maintained that parents would have to give way in order for France to discard the monarchy for republican values.
“From the first moment of life, men ought to begin learning to deserve to live; and, as at the instant of birth we partake of the rights of citizenship, that instant ought to be the beginning of the exercise of our duty. If there are laws for the age of maturity, there ought to be laws for infancy, teaching obedience to others: and as the reason of each man is not left to be the sole arbiter of his duties, government ought the less indiscriminately to abandon to the intelligence and prejudices of fathers the education of their children, as that education is of still greater importance to the State than to the fathers: for, according to the course of nature, the death of the father often deprives him of the final fruits of education; but his country sooner or later perceives its effects. Families dissolve but the State remains.”
This philosophy stands in stark contrast with that of John Locke the English philosopher who believe that the government had no role whatsoever in the education of children. Lock believed that nature granted instructions solely to parental power, not the civil government. And it is interesting to observe how in England today the law reflects this philosophy by granting great freedom to British citizens to homeschool without oversight or intervention from the British government whereas in France homeschooling is legal but is highly regulated and overseen by inspectors from the national education establishment.
Of course we all know that the most tragic application of this philosophy that it is the state's role to shape society and therefore educate children as the future of society was in Germany during the 1930s and 1940s when Adolph Hitler nationalized the education system and criminalized parents who did not send their children to the public schools. For Hitler the "youth of today are the people of tomorrow". He knew that if he got the children he got the culture. He said this "When an opponent declares, “I will not come over to your side,” I calmly say, “your child belongs to us already... What are you? You will pass on. Your descendants, however, now stand in the new camp. In a short time they will know nothing else but this new community.”
Incredibly echoes of these ideas remain in Germany today where public policy makers and judges stubbornly refuse to permit parents to homeschool their children.
In 2003, the German court system reviewed a case of a German family who wished to homeschool their children. The family was denied an exception to the compulsory school law by local education authorities and received a civil fine. The family appealed the fine to the German Constitutional Court which upon review wrote that the “general public has a justified interest in counteracting the development of religiously or philosophically motivated ‘parallel societies’ and in integrating minorities in this area.” Despite the assertion to the contrary in the United Nations’ Universal Declaration of Human Rights, the German court said that parents do not have a prior right, but rather share an equal claim with the State in the education of children:
Social confidence in dealing with people who have different opinions, lived tolerance, the ability to assert oneself and the assertion of a conviction that differs from that of a majority opinion can be practiced more effectively if context was society and with the various views represented in society do not take place only occasionally, but rather are part of the everyday experience associated with regular school attendance.
This is frightening language from a country with Germany’s history. What is perhaps just as frightening is the result of an appeal from a German case to the European Court of Human Rights in 2006. In this case, the Konrad case, the Court denied the family’s application stating that Germany was within its “margin of appreciation” to ban homeschooling. In reviewing the case, the Court noted that the German position--that the State had an interest equal to the parents in the education of children--was not a problem. The Court stated that refusing to hear the case was “justified under Article 8 § 2 and Article 9 § 2 respectively as being provided for by law and necessary in a democratic society and in the public interest of securing the education of the child.” The court rejected the Konrads’ application as “manifestly ill-founded.” I do understand that the religious overtones in this case was probably a bit too much for the German and European Judges. But in a similar case in the United States the Romeike Family was granted political asylum because of the way Germany treats homeschoolers as a social group.
We see this attitude in other countries also.
Real Life Examples of Homeschoolers Being Threatened
Here are some examples:
Spain: The Sala-González family of Alicante, Spain faces a September 9 court date over homeschooling, despite the fact that social workers in the case have reported favorably on the family. Spanish prosecutors insist that the family is breaking the law by educating their child at home. Since December 2010, when a vague ruling from Spain’s Constitutional Court put families in a legal limbo, more Spanish homeschool families are facing trouble with social workers and education authorities. Although homeschooling is not explicitly prohibited, officials also argue that homeschooling is not explicitly permitted by their compulsory attendance laws. This is not an isolated situation in Spain but rather an increasingly common one.
Germany - I have been working on behalf of freedom for German homeschoolers for five years. There have been countless cases of homeschooling parents in Germany threatened with court action including imprisonment, crushing fines, and even with the loss of custody of their children. I have been on the phone with parents who have had to fully with only hours notice from Germany to other countries. The situation continues.
Sweden: in Sweden, a country known for its "social utopia", officials from the island community of Gotland took Dominic Johnson from his parents. The family were on board a jet liner moments before takeoff as the family was moving to the mother's home country of India. It has been over two years and since November the family has not seen Dominic once. How can you describe this as anything but psychological torture? Last year, the Swedish Parliament passed a law that permitted homeschooling only under extraordinary circumstances and made it possible for parents to be criminally prosecuted. Homeschooling families from Sweden are now having to leave the country in some cases under the pressure from social services investigations.
I could literally go on for hours talking about the cases and situations around the world where homeschoolers have been repressed, isolated, persecuted and harassed by their government.
It is this statist philosophy, specifically the Nazi philosophy that led directly to the Universal declaration of human rights in 1945. As a global community nations recognized the need to establish certain baseline standards for the treatment of humanity. And among these was the right of parents to choose freely and without state interference the form of education for their children.
Today we are gathered here in Spain, the largest such gathering in the history of the modern Spanish homeschooling movement – good for you! Here we are gathered as a group of parents who believe in the freedom of education and that all children should have a right to be homeschooled - that parents should be able to decide to homeschool their children without unreasonable interference from the government.
Around the world more and more parents want to homeschool their children. They are dissatisfied with all of the other alternatives and, perhaps more important, they want their children to enjoy the benefits that homeschooling provides.
Different Countries Same Objections
However, all of us – even in America where homeschooling is quite accepted and free homeschoolers are confronted with difficult challenges. These challenges come from government officials and their fellow citizens. As I have traveled internationally and met with many homeschoolers, public policy makers, and members of the media and press I have found that regardless of the country or the context the objections to homeschooling remain virtually the same.
These three objections focus on “academic outcomes”, “teacher competency” and “socialization.”
Academic outcomes has to do with what, how much and how well children learn. Never mind that public schools are failing in this area – we won’t get caught up in comparisons. “Teacher competency” essentially says that mothers (who, in nearly all cases, do the teaching at home) are not qualified to teach their children. How, the question goes, could a mere mother who has no specialized training in education or even a college degree in many cases possibly match the educational outcomes that supposedly come from the teaching of a college-educated, trained and state-certified public school teacher? “Socialization” is usually couched in terms of the need for children to go to school with children their own age in order to learn how to “get along.” This objection comes with a related objection about the lack of oversight and potential for undetected physical abuse or neglect of homeschooled children who are “off the radar” - meaning that because they don't go to school “no one” sees them.
As homeschooling grew in America education professionals observed the fast growth of the homeschooling movement concern and shock. Here is what some of the leaders in the educational establishment said about the homeschooling movement in America over the years.
National Education Association’s Robert McClure said that “it’s important for children to move outside their families and learn how to function with strangers,” expressing fear that home education would undermine commitment to American pluralism. Omar Norton of the Maine Department of Education stated that “instruction in isolation cannot compare with a child being educated in a group.” Texas Federation of Teachers President John Cole observed that “if anyone can teach, teaching will, indeed, no longer be a profession.” Donald Venus, a supervisor of public instruction in Michigan, put it this way: “If you need a license to cut hair, then you should have one to mold a kid’s mind.”
Education professionals were not alone. When asked in a Gallup survey whether homeschooling was a good or bad thing, only 16% of the American public in 1985 said that it was good. That number rose to 41% in 2001. Today I would say that number is well over 60% perhaps as high as 75% - However, as the 16% in 1985 illustrates, not many people were enthusiastic about homeschooling in the early years.
How did this change in perception occur? How were we in the United States able to overcome these objections – mostly the same ones that virtually all homeschoolers all over the world have to deal with?
We overcame these objections with facts, evidence and convincing argumentation. It didn’t happen overnight – in fact it took a really long time. My hope is that you will be able to benefit from our experience and that public policy makers in some countries will be willing to examine the American experience with homeschooling in order to come to the same conclusion that all of our states came to – that homeschooling ought to be allowed. I know that some European policy makers are quite stuck up when it comes to looking at the United States. And of course every country is different and has its own culture and of course must solve its own problems within its own people. But are American children so different from Spanish or Bulgarian or Russian children that general findings are irrelevant? I don’t think so.
Research Results are in Academic Performance and Social Competency
After 30-plus years of increasing experience, scientific research is providing strong evidence exposing the flaws in these criticisms. Research conducted by Dr. Brian Ray has consistently shown that academic outcomes are not significantly related to the training or educational status of the teacher. Dr. Robert Kunzman is a professor of education at Indiana University and specializes in researching the homeschooling movement. He says that more than fifteen hundred articles have been written since 1919 about homeschooling, most of them since 1975. with nearly 200 written on the academic performance of homeschooled students. These studies address the issue of academic performance. Several researchers have surveyed tens of thousands of homeschooled students dating back to 1990. These works include a study by Dr. Brian Ray and Dr. Lawrence Rudman and show that homeschooled students’ academic performance on standardized tests are generally as much as 25 to 35 percentile points higher than the average public school students’. These reports can be accessed at the Home School Legal Defense Association’s website (www.hslda.org/research). The studies have found that there is no or only minimal correlation between a homeschool teacher’s credentials or qualifications and the academic performance of the child. Essentially, this meant that a homeschooling mother who did not have a high school diploma and any homeschooling mother who had a Ph.D. would, on average, achieve similar results. Students taught by both were 25 to 35 percentile points higher than the national average representing public school students.
Dr. Kunzman also reports that over 220 articles have been written regarding socialization of homeschooled students since 1984. One 2003 study by Dr. Ray surveyed nearly five thousand homeschool graduates. In “Home Educated and Now Adults” Dr. Ray found that homeschooled students were more civically active and participated in more extracurricular activities than the average public school student. Dr. Ray’s research shows that homeschooled children go to college, enter the workforce, become active in politics and are highly involved in their communities at rates equal to or higher than their peers in other educational settings. Another study performed by Dr. David J. Francis and Dr. Timothy Keefe, published in 2004, found that the social skills and competencies of homeschooled children as measured on standardized tests were as good or better than public school children. Dr. Richard Medlin offers the most recent synthesis of research on the social, emotional, and psychological development of the home educated. In his work Dr. Medlin found that home educated students are active and well-adjusted. These findings make sense when one looks below the surface to see how homeschooling works.
In homeschooling, children are not tied to a set schedule or physical brick-and-mortar location. Homeschooling is in many cases as much a lifestyle as it is a form of education. It allows for far greater flexibility for children to follow their own interests—to a much greater extent than most public school children are able to do. News reports frequently highlight homeschooled students who have made notable accomplishments in large part because they were not tied to a traditional educational setting. For example, in July 2009, homeschooled teenager Zac Sunderland became the youngest person to circumnavigate the world. Actor Will Smith and his wife Jade explained to Essence magazine that they homeschool their children because it allows “for flexibility so they can stay with us when we travel and also because the school system in this country—public and private—is designed for the industrial age. We’re in the technological age. We don’t want our kids to memorize. We want them to learn.” Homeschoolers have also won a disproportionate number of national science, math, spelling, geography, and other academic competitions.
So these are the basic challenges. They are not small and they make take years to overcome. In countries where homeschooling is just getting started it is easy for people to feel isolated and alone and that they should just give up. But there is no need for this especially when as a global movement with much in common we can support one another.
I can tell you that our 82,000 member families care about you. They care about your families and about your movement. We have been helping families all over the world who are in trouble. Why you may ask – why does an American organization care about homeschoolers around the world. Well first of all you know how we Americans just can’t keep our nose out of other people’s business. After a couple of hundred years of keeping to ourselves we now just can’t mind our own business. J But seriously - it is part of our associations mission to advance the cause of homeschooling. More than just altruism which for me is certainly sufficient reason, there is a pragmatic rationale for why American homeschoolers should care what happens to their comrades overseas.
Ideas travel very quickly over the Internet. And these notions that homeschooling is dangerous or should be restricted must be resisted wherever and whenever they appear. So if we let the German and Swedish authorities get away with persecuting homeschoolers authorities in our country over time might try to use their arguments as reason to further regulate us. After all the German school system was a model that the early education professionals in America used to develop our education system.
More than this however is that we have been blessed with great freedom and resources in our country. And we believe that it is our duty to help those who are oppressed, the inscription under the statute of liberty in our country, given to us by our French compatriots says “Give us your poor, your tired, your huddled masses, yearning to breathe free”. America homeschoolers know what it is like to suffer because of homeschooling. And we know that it helps to have support.
In the United States, homeschoolers have been able to change public perception by engaging in the Democratic legislative process to change laws but have also engaged in the public debate through the media. If we work together we can make a difference in countries where homeschooling is just getting started. While America may have the largest population with greater resources, we cannot and should not do it alone. Because It makes a difference when homeschoolers from all over the world get involved - it shows that it is not just those troublesome meddling Americans. Even If only to provide moral support and encouragement to the few homeschoolers. But our experience suggests that international contact does help.
For example, in February 2011, letters from HSLDA members and supporters of homeschooling around the world made a difference in the lives of the Vitoria-Gasteiz family convincing the court to drop charges of educational neglect against a Spanish homeschool family.
ALE brought this family’s situation to our attention and we worked together to encourage homeschoolers in Spain and elsewhere to write to the judge who would hear their case.
“The support from around the world made all the difference,” ALE representative Daragh McInerney told HSLDA. “It showed the court that homeschooling is simply another educational option, not a dereliction of one’s parental duties.”
“The local court has asked us to spread the word that the family’s case is over, so they will stop receiving letters and faxes—hundreds have arrived,” says McInerney. “Hopefully there will be more good news on the way soon for other families facing legal proceedings.”
In this experience has been repeated in other countries like Botswana, Sweden, Germany, Russia, England and elsewhere. Public policy makers and government officials are simply unaware about the facts of homeschooling. These individuals have been brought up in an environment which assumes that the state should be and is virtually all-powerful and that it is a matter of course that children must go to the public school. By providing arguments and information against the objections to homeschooling I have described above both in specific cases and in general we are able to help individual homeschooling families and homeschooling as a movement in all of our countries. By pointing out that Freedom in education is and ought to be treated as a fundamental human right we build a stronger foundation for freedom for all of us all over the world. By fighting threats to freedom especially in western democracies like Sweden and Germany and Spain, we can develop the ability to defend others while helping our own cause.
This is fairly easy for us to do. We have sponsored and published research, written letters to members of parliaments, to minsters of education, to ambassadors, we have helped support legal cases – some have lost but some have won. We have helped families flee oppression. We would like to be an encouragement to others because we know what a difference it makes to know that there are people out there thinking of you, praying for you and fighting for you. We can do these things, but ultimately success in each of our countries can only be achieved within each country’s political system. This success requires patience and persistence. You have keep going back to policy makers with the same arguments., to the media. To your neighbors. You have to be tireless and gracious. But if you will do this I’m confident that you will be successful. One of the founders of our country, Samuel Adams once said that it does not take a majority to prevail but only a tireless minority willing to constantly set brushfires in the minds of their neighbors. This is what homeschoolers everywhere must do. And there is one thing that is certain of course, that if you give up you will never succeed, but if you never give up, you can’t help but succeeding.
Thank you for your kind attention! May God bless you and your families!
 Presented September 3, 2011 at the Spanish National Homeschooling Conference In Gandia, Spain.
 Charles Glenn and Jan De Groof, Balancing Freedom, Autonomy and Accountability in Education, (Nijmegen, Netherlands: Wolf Legal Publishers, 2005), 1.
 Ibid., 7.
 Martha Albertson-Fineman and Karen Worthington, What is Right for Children? (Burlington: Ashgate Publishing Company, 2009), 235.
 In the case relating to the constitutional complaint of Mr. Konrad, German Federal Constitutional Court (1 BvR 436/03, decided 04/29/03).
 European Court of Human Rights, application no. 35504/03, October 2006, by Fritz Konrad and Others against Germany, 9.
 Gaither, 181.
 Ibid., 182.
 It does not appear that the poll question has been repeated more recently. However, it is probably not a stretch to suggest that the results of a current poll question would likely top the 50% “good” barrier.
 Robert Kunzman, Homeschooling Research & Scholarship, http://www.indiana.edu/~homeeduc/research_homepage.html (accessed May 17, 2011).
 Home School Legal Defense Association and Brian Ray, “Home School Progress Report 2009: Academic Achievement and Demographics,” (2009), see http://www.hslda.org/docs/study/ray2009/2009_Ray_StudyFINAL.pdf.
 Brian D. Ray, Home Educated and Now Adults: Their Community and Civic Involvement, Views about Homeschooling, and Other Traits, (Salem, OR: National Home Education Research Institute, 2004).
 David J. Francis and Timothy Z. Keith, “Social Skills of Homeschooled and Conventionally School Children: A Comparison Study,” The Homeschool Researcher 16, No. 1 (2004): 15-24.
 Medlin, Richard G. (2006). Homeschooled Children’s Social Skills. Home School Researcher, 17(1), 1-8.
 Gaither, 221.
 Michael P. Donnelly, Brief Of Amicus Curiae Home School Legal Defense Association, Christian Home Educators Of New Hampshire, And Catholics United For Home Education In Support Of Petitioner, May 14th, 2010, State of New Hampshire Supreme Court , Record no. 2009-0751, In The Matter Of Martin F. Kurowski, And Brenda A. Kurowski, http://www.hslda.org/hs/state/nh/NH_Amicus_Brief_5_19_2010.pdf (accessed May 17, 2011), 9-14.
Copyright Michael Donnelly Esq. Reserved copy and reproduce with permission only.