jected by the Michigan Supreme Court, regarding certification as a minimal burden that was outweighed by the State's interest in providing proper education. In People v. DeJonge parents claimed the right to educate their children at home, as an exercise in religious freedom. The court upheld the state law ruling that the state's interest in educated citizens outweigh the rights claimed by the parents (Fischer, 1995). In a related Michigan case, People v. Bennett (1983), the State Supreme Court ruling involving home-school families that had been convicted of violating the compulsory education statute, was reversed from he lower courts decision. The State Supreme Court permitted religious home schooling on First Amendment grounds and curbed the power of education officials to review home schooling policies (Clark, 1994). The other constitutional attack on compulsory attendance laws is non religious, primarily on Fourteenth Amendment due process grounds that parents have the right that is, the liberty, to educate their children as they see fit (Richardson, 1991). This right argued parents is superior to the state's right to compel attendance and regulate education. In Scoma v. Chicago Board of Education (1974), Blackwelder v. Safnauer (1988), and Murphy v. State (1988), the courts specifically rejected the contention that the parents had an independent, non religious, fundamental right in educating their children. In Scoma, the parents sought an injunction and declatory judgment to prevent the Chicago Board from interfering with their decision to educate their children at home. Under the Pierce and Yoder test the Illinois federal district court said the statute is reasonable and constitutional (Richardson, 1991). Now that home schooling s allowed in all 50 states, thenext step for these parents is to incorporate their children's' home schooling with public school activities. One such instance is in Iowa that started the Home Instruction Pr...
