03.07.08
California Homeschoolers in an Uproar over Appellate Ruling
A ruling came out of California’s Second Appellate Court last week, in re Rachel L., that if read quite broadly, denies everyone but credentialed teachers the right to homeschool their children in this state:
“California courts have held that under provisions in the Education Code, parents do not have a constitutional right to home school their children. Thus, while the petition for extraordinary writ asserts that the trial court’s refusal to order attendance in a public or private school was an abuse of discretion, we find the refusal was actually an error of law. It is clear to us that enrollment and attendance in a public full-time day school is required by California law for minor children unless (1) the child is enrolled in a private full-time day school and actually attends that private school, (2) the child is tutored by a person holding a valid state teaching credential for the grade being taught, or (3) one of the other few statutory exemptions to compulsory public school attendance (Ed. Code, § 48220 et seq.) applies to the child.” (page 3)
In California, there is no “homeschooling”. There is public schooling, compulsory attendance to which is required of children aged 6 to 18; and there are a few exemptions to compulsory attendance. The pertinent exemptions from this case are listed in Ed. Code Section 48220ff. Children can be exempted from attendance by one of two paths: credentialed tutoring or private schooling. The tutoring exemption is very specific, requiring an appropriate state credential as well as regulated hours of instruction. The private school exemption (48222 in the above link) is far more general:
- “Children who are being instructed in a private full-time day school by persons capable of teaching shall be exempted.”
- Teaching must be in English, with certain exceptions.
- The school must “offer instruction in the several branches of study required to be taught in the public schools.”
- Attendance must be kept, including all absences half a day or greater.
The exemption is valid after the attendance supervisor or similarly designated official confirms that the private school is in compliance with Section 33190, the private school affidavit statute, which requires an annual filing with the state. (In practice, I don’t believe any district verifies the private school exemption proactively for every private school student; that would be incredibly costly in staff and funding each year. The exemption is only verified if an attendance challenge is made.) Interestingly,
“The verification required by this section shall not be construed as an evaluation, recognition, approval, or endorsement of any private school or course.” (48222 again)
This is echoed in 33190:
“Filing pursuant to this section shall not be interpreted to mean [legal jargon about what "mean" means] … that the State of California, the Superintendent of Public Instruction [etc.] … has made any evaluation, recognition, approval, or endorsement of the school or course … “
These clauses emphasize the determination of the state to avoid interference in the educational operations of private schools. Private schools are therefore free to pursue with broad discretion the type of education they choose, both in content and in methodology. A school is free to teach young earth creationism or to implement the free democratic school philosophy (e.g. Sudbury Valley or Summerhill strategy), or other content or methodology as they wish.
In practice, the combination of the private school exemption and the very limited private school regulations (essentially an hour or two of paperwork each year for a tiny, two-student school such as I operate) have formed the foundation for independent homeschooling in this state. There is nothing in California law, statutory or judicial, that restricts the establishment of a private school as done by homeschoolers here. No law
- says a private school can’t be located in a private residence.
- says a private school must charge tuition.
- says a private school must have a minimum number of students.
- says a private school teacher can’t instruct their own child(ren). (In fact, the criminal background check provision for school personnel states explicitly that it is waived for a parent working exclusively with their own child(ren).)
- says a private school can’t have one adult who is principal, faculty and staff simultaneously.
Although the recent ruling has every homeschool e-list in the state, and many more around the country, wildly abuzz with strategic discussion and well-informed indignation, in a strict reading the Second Appellate Court has changed only one aspect of California’s education law. In a Bill Clinton-esque (someone else’s beautifully appropriate adjective) application of semantics, the private school exemption statute was interpreted to mean that a student must be in physical attendance at the private school:
“Section 48222 provides an exemption from compulsory public school education for ‘[c]hildren who are being instructed in a private full-time day school.’ (Italics added.)” (ruling p.15; italicized emphasis of “in” is part of the ruling, just to be clear!)
The children in the case, while enrolled in a private school, participated in that school’s independent study program (ISP). The school in question does in fact have a campus program as well, but there are many ISP-only private schools throughout the state serving homeschoolers exclusively. What the Second Appellate Court discovered is that there is no law (pro or con) governing the authority of a private school to offer independent study. There is only Ed. Code 51745, which gives authority to public school districts and county boards of education to establish ISPs (presumably but not explicitly within the public system).
It is important to note that this case does not arise solely from a compulsory attendance challenge, but from the family’s frequent intersection with various child protective services. This particular case was instigated by one of the children on behalf of herself and I believe two of her siblings, for various reasons of neglect and/or abuse. Their court-appointed attorneys wanted them in a traditional school facility, where they would be under the regular observation of more adults; this would presumably give them more protection against said neglect and/or abuse. The trial court ruled that the parents have a constitutional right to homeschool, and the appellate court overturned that ruling of law, with the full documentation of statute and precedent.
I have concluded, from reading through the various documents and statutes, that my own homeschooling choice (to run a private school) is not affected by this ruling. I am in compliance with all the private school regulations, and my children attend, on-site, a private school within the exemption guidelines ruled in this case. I do not expect district officials to come to my door demanding truancy proceedings on my kids.
Notwithstanding the legitimacy of my own homeschooling method, I believe this ruling makes an unfairly strict interpretation of the private school exemption by denying the right of a private school to offer independent study. Since independent study is explicitly organized for the public schools in 51745, the state obviously believes it is acceptable for a student to do the bulk of their learning away from the direct supervision of their official school teacher. Given the minimalist statutory regulation of private schools in California, quite the opposite of this ruling makes better sense: that there is an implied right for a legally compliant private school similarly to offer independent study. Independent study by definition reduces a student’s exposure to their teacher; whether that teacher is public and credentialed, or private and “capable of teaching”, makes no difference. The court could easily have ignored or rejected the parents’ “constitutional right to homeschool” argument and made the case under welfare law that it was “in the best interests” of the children that they be enrolled in a traditional school.
State Superintendent Jack O’Connell went on record in response to media inquiries about this ruling that he supports “parental choice when it comes to homeschooling”, which is a bit vague but still a reasonable comment, unlike the teachers’ union officials who have cited the ruling in support of their belief that all students should be taught by a credentialed teacher, obviously in complete ignorance of CA private school regulations. Governor Schwarzenegger went on record more vehemently, calling the ruling “outrageous” and for it to be overturned by the courts or by new legislation. This support from state officials is greatly appreciated, though there is rampant speculation that they are less motivated by concern for parental rights, and more concerned with the reality that 166,000 homeschooled kids at more than $7500 per child means the state would need to find $1.245 billion merely in ADA funding (average daily attendance), to say nothing of facility space for all those kids, at a time of universal cuts to balance a state budget with a shortfall of $7 billion or more.
The assorted homeschooling advocacy groups concerned with California issues (I belong to both HSC and CHN and there are others) are strongly against legislative action and are recommending that individual homeschoolers sit tight while the legal eagles work for a milder, but still thorough, resolution to the issue. (In general, legislation is not desired because it always comes with extensive hoops that detract seriously from the efficacy of homeschooling; the most intrusive and most common is standardized testing, which as we see in the public schools causes “teaching to the test” and erodes true education and learning.) These advocates have agreed to seek from the CA Supreme Court the “depublication” of the ruling; this step would have the ruling limited to the troubled family at issue in the case, thereby denying its broader application vis a vis the statutory interpretations.
I strongly support this action as promoting both an affirmation of the rights of California homeschoolers and a positive resolution for the children at risk in the case. I have made a financial donation to the legal effort, and have offered my time and energy as a volunteer to the various legal and media teams. (I did a pre-interview with a TV reporter this morning but the manager didn’t approve his story; this afternoon, I spoke on record with a reporter for the Fresno Bee.)
If you are interested in making a financial donation to support the effort, here are the direct links for that: HSC CHN
Links to articles and statements about the case: