Home School Court Report
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Vol. XXV
No. 1
Cover
January/February
2009

In This Issue

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Germany - It's Time for Some Change

In January of 2008, the Jugendamt (Germany’s youth welfare office) and police officials surrounded the Gorber family’s Uberlingen home in a surprise raid. Mr. Gorber was away from home at the time of the raid, visiting his wife at a local hospital where she had been admitted, due to complications from her pregnancy with their ninth child. Despite the children’s repeated protests, all but the oldest son, age 21, and a daughter, age 20, were taken into custody by the authorities.

The siblings reported that the 7-year-old was gripped around the waist by a youth home music teacher, dragged kicking and screaming across the courtyard, and thrown into a van. The terrified 3-year-old clung to his 20-year-old sister so tightly that even the police and Jugendamt official could not separate them. Both had to be taken to the youth home, where at last the little fellow’s strength gave out and he was taken into custody.

The children received psychological exams, which reported that they were all normal and well-functioning. Although these evaluations attested to appropriate parenting, the judge at the Gorbers’ trial indicated that he was unwilling to allow the five children of school age to return home, because he did not believe the father’s assurances that he would enroll the children in school.1

After a 10-month ordeal, a judge restored custody of the children to the Gorber parents, but ordered that the children be enrolled in public school and the 3-year-old participate in a playgroup for “socialization outside the family.”2

Why Should American Homeschoolers Care?

For homeschoolers, Germany isn’t a friendly place. German authorities routinely fine, jail, and remove children from homeschooling parents. An outsider might wonder where this behavior comes from—is it rooted in some unique aspect of German culture? Could America or other western countries be influenced and begin acting like this? What, if anything, can be done about this grossly disproportionate treatment of a small group of parents who are simply seeking to educate their children at home? What is so threatening to German authorities about a few hundred (or even thousand) families swimming against the stream of the popular culture?

Even as it appears that freedom for American homeschoolers is secure, we would do well to remember that, not long ago, homeschooling parents here were facing truancy charges, jail, or loss of custody. Recent events like the Rachel L. case in California and annual state legislative battles illustrate that, while homeschooling may seem safe in America, there are those who constantly seek to restrict the freedoms homeschoolers now enjoy.

In a world where distances have been compressed through information technology, events from all over the world can impact us here. And, as international law and opinion influences American courts and policy makers, we must pay attention to the experience of homeschoolers in other countries. One of HSLDA’s missions is to make sure that the German experience does not migrate here. We also hope and pray that Germany’s homeschool experience will parallel America’s, where, over time, freedom came to homeschooling parents.

Why is Germany Persecuting Homeschoolers?

Germany’s Basic Law, similar to our own federal Constitution, states, “the care and upbringing of children is the natural right of parents and a duty primarily incumbent upon them. The state shall supervise them in the performance of this duty.”3 In interpreting this provision of the Basic Law, Germany’s Federal Constitutional Court “stressed that the State’s obligation to provide education did not only concern the acquisition of knowledge, but also the education of responsible citizens who participate in a democratic and pluralistic society.”4

...
HOWEVER, ALL
TOO OFTEN, THE
MODERN STATE DOES
TAKE ON A ROLE
OF SHAPING SOCIETY.
...

These provisions of Germany’s Basic Law are interpreted by the courts to prohibit homeschooling. When he sentenced Juergen and Rosemary Dudek to 90 days in prison for homeschooling, Judge Becker, a county court judge in the state of Hessen, wrote in an unpublished opinion on July 22, 2008, that education is “not only a passing on of knowledge and skills” but that public schools “serve as a suitable and necessary instrument to…not only…pass on knowledge but to bring [up] a responsible person.” The school is responsible for “rearing up responsible citizens who will equally and responsibly participate in the democratic processes of a pluralistic society.”5 And compulsory public school attendance is necessary to create “social competency in relationship with people who think differently, practice tolerance….” School attendance “fulfills the general goal of [this] integration.”

Judge Becker goes on to defend the necessity of public education:

The general public has a legitimate interest to work against the development of any religious or other ideologically motivated parallel societies and to integrate minorities. This integration does not only take for granted that the majority of the population doesn’t marginalize religious and ideological minorities, it also demands that they don’t marginalize themselves and that they don’t close themselves off from a dialogue with people of different views and beliefs. The presence of a wide spectrum of convictions in a classroom can effectively further the ability of all students to more tolerant dialogue as a prerequisite of the democratic process of the formation of the will.

According to the interpretation of the German courts, homeschoolers, by withdrawing their children from public education, subvert the state’s effort to foster pluralism and tolerance. This threatens what the state sees as its interest to create “responsible citizens.”

Germany’s History of Mistreating Minorities

Homeschoolers are not the first minority group that Germany has considered a threat. Seventy to eighty years ago, Adolph Hitler, the German fuehrer, used a racist form of fascism to eliminate Jews, blacks, Catholics, handicapped persons, and other “minority” groups. No one argues that the plight of homeschoolers in Germany even begins to compare to what was suffered by those minority groups in Germany before and during World War II. And modern Germany is clearly not to be compared to Nazi Germany.

The Gorber Family
Bringing encouragement: Reinhardt Klett (second from right) and Mike and Peter Donnelly (center) meet with the Gorber family.

Yet, in light of this history, it is difficult not to wonder why modern German authorities treat homeschooling parents this way. What is it about Germany that enables such uniform and repressive measures against parents and families who seek to home educate? Exorbitant fines in the tens of thousands of dollars, jail time, and court hearings to take away custody are the tools nearly all German authorities are using to repress homeschooling.

This is especially out of the ordinary when nearly all other western European democracies allow for homeschooling by either constitution, law, or practice. Even formerly communist eastern European countries are loosening up their laws and regulations to allow homeschoolers freedom. Far from escaping the rigidly uniformitarian ideas about society that prevailed in Hitler’s Germany, today’s authorities seem to be perpetuating it through their treatment of German homeschoolers.

Side by Side: Pluralistic or Parallel Society?

The view of homeschooling as a threat seems to stem from modern Germany’s understanding, or perhaps misunderstanding, of pluralism and a concern over parallelgeselsschaft or “parallel societies.” Judge Becker noted that it is the role of the Federal Commission on Education to “rear up responsible citizens who will equally and responsibly participate in the democratic processes of a pluralistic society.” He also noted that “the general public has a legitimate interest to work against the development of any religious or other ideologically motivated parallel societies and to integrate minorities.”

But how does pluralism allow for this treatment of homeschoolers? Isn't pluralism supposed to stand for tolerance of different people?

Human Rights in Pluralistic Societies

Pluralism, defined by the dictionary as the “existence of different groups within society,”6 is used in many contexts to describe diversity within a particular system or environment. People talk about political pluralism, educational pluralism, philosophical pluralism, and religious pluralism.

True pluralism protects the human rights that have been the basis for free societies across the world. The American Founders appealed to the notion of natural rights as coming from the Creator of the universe in the Declaration of Independence, when they wrote,

When in the Course of human events it becomes necessary for one people to dissolve the political bands which have connected them with another and to assume among the powers of the earth, the separate and equal station to which the Laws of Nature and of Nature’s God entitle them, a decent respect to the opinions of mankind requires that they should declare the causes which impel them to the separation. We hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness.[emphasis added]

What Pluralism Really Means

A freely elected democratic government, such as the American Founders envisioned, does not exist to form or mold society; it exists to protect the rights and freedoms of its people from internal and external threats and to apply the rule of law equally to all.

The Dudek Family
Despite ongoing persecution, Juergen and Rosemary Dudek have been homeschooling their children since 1998.

However, all too often, the modern state does take on a role of shaping society. It does this under the leadership of political organizations that seek to further their own society-transforming agenda—and increasingly toward some form of socialism. Because the state has coercive power through its functions to make and enforce laws, it has the power to shape society if, at least in democratic societies, it can obtain a majority.

Within a democratic political context, however, true pluralism stands for the idea of many different groups co-existing and cooperating peacefully within a common society. This understanding includes two important implications.

First, a common political society must exist. At a minimum, there are five elements that ought to be shared by a common political society: common boundary, common language, common economic system, common legal system, and common political authority that reflects the will of the people with respect to laws that apply equally to all. Without these common structures, there is no common society—merely different groups living autonomously within a geographic area.

Second, for different groups to exist, these groups must have something that makes them distinctive, be it racial, cultural, ethnic, religious, or philosophical. If there aren’t distinctions, then there is just one big, homogenous group—and that isn’t pluralism. Again, pluralism is defined as the existence of different groups within society.

Applied Pluralism

How governments interpret pluralism and human rights varies, however. The European Convention on Human Rights, to which Germany is a signatory, states that “No person shall be denied the right to education. In the exercise of any functions which it assumes in relations to education and to teaching, the State shall respect the right of parents to ensure such education and teaching in conformity with their own religious and philosophical convictions.”7

The Busekros Family
In 2007, then 15-year-old Melissa Busekros (second from right) was forcibly removed from her family because she was homeschooled. Officials in a psychiatric ward claimed she had “school phobia.” Early the morning she turned 16—knowing she now had legal rights to decide where to live—Melissa left her foster home to return to her family. The state later billed the Busekroses for Melissa’s forced stay in the psychiatric ward. Mike Donnelly and son Peter (far right) are pictured with the family.

In Article 26 section 3, the UN Declaration of Human Rights provides that “Parents have a prior right to choose the kind of education that shall be given to their children.”8

So, say the German authorities, you can have your rights as parents to choose whatever form of education you think is best for children—as long as you pick our public schools. Or you can pick among the few private schools that have been approved (by us). Or if you want to teach your own children, you can do it—just do it after school hours or on weekends.

In Germany, the government applies its police power to enforce its version of parental rights. In 2007 in the Paul & Plett case, the Bundes Gericht Horst (Germany’s highest criminal appeals court) ruled that parents who homeschool are guilty of abusing their parental rights. This is important, because such a determination allows the Jugendamt to allege that homeschooling parents are abusive and to remove children from their custody. This case is being appealed by the International Human Rights Group to the European Court of Human Rights in Strasbourg.

German courts have reasoned that the state’s interest in integrating children into society is more important than the German parents’ right to decide what is best for their children.

Real Parallel Societies do Create Legitimate Threats to Pluralistic Societies

This compelling state interest stems from Germany’s fear of parallel societies, groups of people who live within the common political society but do not share the minimum common characteristics. These subsocieties within the larger society do not seek to interact but rather to remain isolated. Such a parallel society limits contact with the common political society and seeks to operate and perpetuate its own civic institutions and legal functions, perhaps even rejecting a common language.

European Parliament Member Kathy Sinnott
A champion for homeschooling freedom in the European Parliament, Irish MEP Kathy Sinnott poses with Peter and Mike Donnelly.

If we accept the idea that government exists to maintain order by establishing a rule of law that applies equally to all within its jurisdiction, then, indeed, parallel societies are dangerous. In such parallel societies, the rights that should be protected and enjoyed by all citizens of the society could be repressed in the name of some other philosophy, legal system, or religion, perhaps. If this were true, it would mean that not all citizens would receive equal protection under the law. Because it is the duty of the state to protect the rights and equal application of the law to all people living within its jurisdiction, this cannot be allowed.

For example, the idea of Islamic subpopulations that apply religious law within their geographic boundaries and foment radical Islam are a concern for German authorities because of the large and growing Islamic population in Germany. There are documented cases of persecution of foreigners in Germany in particular Muslim communities. But, while parallel societies may indeed be an enemy of a democratic society, dogmatic and coerced uniformity by government is the enemy of a pluralistic society.

Homeschoolers Do not Create a Parallel Society

So are homeschoolers really a parallel society? Do homeschooling families isolate themselves from a common language, a common law, and a common set of civic institutions or even an economic system? Empirical data and research clearly establish that this is emphatically not the case. While homeschoolers may not participate in the public education system, this does not make them a parallel society. Homeschoolers ought be considered a definable social group, but, according to research, they engage at higher levels on average than their public and private schooled counterparts in the civic institutions of free democratic societies, rather than isolating themselves.9

The question is not whether a free society can or must be either democratic or pluralistic—it can and should be both. I would suggest that no responsible homeschooler would advocate for the creation of what I have defined here as a parallel society.

Educational Freedom is Necessary for Pluralism

What we see in German education is not pluralism but rather support of a state-controlled and coercive system of education, whose stated purpose, at least as far as the German judiciary is concerned, is not to promote pluralism but rather to standardize and integrate children into society.

Armin and Gabrielle Eckermann
Armin and Gabrielle Eckermann, founders of Schuzh, discuss legislation and legal strategies with Mike Donnelly.

In Germany, the natural effect of sending children to public schools is to impose a level of nationally (or state-) applied and coercively mandated uniformity. Children study the state-approved curriculum, are institutionalized for a majority of their time with children their own age, and are expected to conform to a nationally mandated set of standards. This is educational uniformity—it strips away distinctives in people groups and undermines a pluralistic society.

Those who would shape society know that in order to do so, they must control education, because the children of today are the culture of tomorrow. Children are impressionable, and those with whom they form the closest attachments will most impress upon them the moral and social norms that they carry into adulthood. Hitler sought to unify German society in the 1930s by abolishing the states, taking control of all private and public education, and requiring that all children attend nationally controlled schools, saying,

The youth of today is ever the people of tomorrow. For this reason we have set before ourselves the task of inoculating our youth with the spirit of this community of the people at a very early age, at an age when human beings are still unperverted and therefore unspoiled. This Reich stands, and it is building itself up for the future, upon its youth. And this new Reich will give its youth to no one, but will itself take youth and give to youth its own education and its own upbringing.10

Sharply contrasting with that view, the United States Supreme Court in the case Pierce v. Society of Sisters penned this famous quote:

The fundamental theory of liberty upon which all governments in this Union repose excludes any general power of the State to standardize its children by forcing them to accept instruction from public teachers only. The child is not the mere creature of the State; those who nurture him and direct his destiny have the right, coupled with the high duty, to recognize and prepare him for additional obligations.11

This is why educational freedom is so important to a pluralistic society. An exclusive and state-controlled system (a monopoly) of education with the purpose to standardize children in the name of “integration” is no friend of pluralism. A nation that coerces unquestioned, unexcepted uniformity in such a critically important area of public life has abandoned the principles of pluralism and individual liberty.

Efforts of German Homeschoolers to Gain Freedom through Legislation

HSLDA has worked with German homeschoolers for nearly a decade to re-establish this educational freedom that marks truly pluralistic societies. Before 1938, parents did have the right to educate their children at home. After Hitler nationalized education and made criminals of parents who did not send their children to the state schools, homeschooling was eradicated. The homeschooling movement began and grew slowly in Germany in the 1980s and 1990s. Then, in 2000, HSLDA helped establish a German homeschool defense organization known as Schuzh. Schuzh is led by a husband and wife team of German lawyers, Armin and Gabrielle Eckermann. Although not homeschoolers, these two lawyers have worked tirelessly to minister to and defend homeschoolers from many parts of Germany.

Because the average homeschooling family in Germany is not wealthy, funding to support litigation and other activities encourages and materially assists German homeschoolers. The Alliance Defense Fund has partnered with HSLDA through grants to help fund important cases that may provide opportunities to bring homeschooling to the public’s attention and that may give the German court system an opportunity to repent of their repressive and harsh rulings against homeschoolers.

In 2006, when the European Court of Human Rights rejected the homeschooling case of Konrad, it became clear to many that, if even an appeal to the European court system failed, homeschoolers could not rely on German courts to deliver freedom. Only change through the legislatures would bring the needed reforms to allow parents to freely homeschool. HSLDA has developed a new strategy of focusing on legislative efforts and creating public awareness as a necessary condition for changing German laws and regulations. This strategy can be viewed at HSLDA’s Germany home page.

Within the past three to five years, other organizations of German homeschoolers have formed with the aim of influencing the public and legislatures to allow homeschooling in Germany. These organizations are meeting with local and national politicians and ministers of education to ask them to help create change to protect the rights of parents to homeschool.

Homeschoolers are Working to Change Public Perception

In 2006, one of these groups, Netzwerk Bildungsfreiheit,12 sponsored a conference in Germany with the European Forum for Freedom in Education,13 a Europe-wide organization dedicated to creating freedom in education across the continent. The conference brought together hundreds of homeschoolers and supporters from all over Europe and was a great encouragement to German homeschoolers. Netzwerk leaders are brave families who, in the face of constant threat of persecution, continue to homeschool their children. The Netzwerk seeks opportunities to meet with German politicians and has been successful at bringing homeschooling to the attention of state education ministers, representatives, and the news media. Another organization, the Bundesverband Naturlich Learning (Association for Natural Learning), sends out newsletters and organizes events to support homeschoolers and bring awareness of the need for change in Germany’s education laws.

Success Comes Slowly

Historically, the news media in Germany has been hostile to homeschoolers, painting them as out-of-touch, ultra-isolationist, radical fundamentalist Christians. In an increasingly secular country like Germany, this is a serious charge. However, in more recent years, some homeschoolers have seen a shift toward growing sympathy in media coverage. This kind of news coverage is vital to changing the stereotype that homeschooling creates dangerous parallel societies. In January of this year, premier German magazine Der Spiegel ran a feature story on homeschoolers, featuring the Dudek and Neubronner families. The coverage of homeschooling was more favorable than ever before.

Some legislators are beginning to take note. In the legislature of the German state Baden Wurttemberg, the minority Free Democratic Party (FDP), which is something like the Libertarian party in America, has taken an interest in homeschooling. In May of 2008, I attended a meeting with one of the FDP parliamentarians, who admitted that the current state of affairs should not continue for homeschoolers and that some form of toleration had to be found so that parents did not have to live in fear of persecution for homeschooling.

International attention may also help persuade Germany to grant more freedom to homeschoolers. Kathy Sinnott, an Irish Member of the European Parliament who has homeschooled her own special needs child, understands the problem. MEP Sinnott has championed petitions from homeschoolers before the 725-member European Parliament’s Petitions Committee. The Petitions Committee hears grievances that citizens have against their governments. After hearing the grievance, the committee votes whether to refer the matter to the Council of Ministers, who then take the matter up with the member state and try to get it to take some action to address the problem. In July 2008, MEP Sinnott—also Vice President of the Petitions Committee—said this about the petition of Rina Groenveld, an Irish homeschooling mother living in Germany because of her German husband’s employment:

This petition brings into question workers’ mobility. One of the guarantees of the internal market is the freedom of movement of workers in the EU. There is an increasing awareness that workers have families and that flexibility to meet their needs should be part of employment law. However, Germany’s approach to home schooling compromises this and forces families to choose between a job and the best interests of the children. The need for family friendly employment policies must be recognized throughout the EU. We need to have flexibility in the education of children temporarily resident because of work. There is also an issue around the attitude to non-German families in the German children’s courts. I hope the dialogue between the Commission and the German State will resolve this discriminatory situation.14

HSLDA is encouraging the American government to take a more vocal position on this human rights issue. Germany is an ally, and we can use our friendship to point out that homeschooling is a freedom that should be protected, not repressed. The experience of scores of countries from all over the world shows that homeschooling supports pluralistic democracy and is not a threat to society.

The Faithfulness of German Homeschoolers

In my conversations with Juergen Dudek, homeschooling father of seven, he never fails to tell me how much it means to him to have the support and encouragement of homeschoolers in America. Juergen and Rosemary Dudek have been homeschooling their seven children since 1998. They have tried to accommodate the government by attempting to register their home as a private school. This forestalled the authorities from taking action against them personally until the state denied the private school application. After this, the local school office decided it was time to “get serious.”

Juergen remembers a pivotal statement from a judge in 2006, handling one of the cases relating to one of their children:

“If your conscience is so important to [you]—then why don’t you just leave the country?” It was our first confrontation with the way homeschoolers were to be taken care of in Germany: just push them out of their homeland when their time comes. When the school authorities realized that we weren’t just fooling around but—despite our fine—went on educating our children at home, they sent our case to the state prosecutor one day before the hearing. This prosecutor and judge took a rather relaxed stance on the issue. They didn’t want to see us heavily sentenced and worked out a fine of 300 euros and demanded that we apply for the status of private school for our homeschool, the criminal procedure being suspended.

In May of 2007, Juergen wrote to me, just days after I met him during a trip to Germany, where I presented a paper in support of homeschooling.

I’ve been wanting to write you since our return from Burg Rothenfells at the end of April. Once again, thank you for your talk on “Pluralism and Parallel Societies.” Remember, you gave me your manuscript? I tried to make use of some of its points for our defense just a couple of days later, but it all just didn’t matter. The only thing that mattered was: “Your kinder (children) are going to school tomorrow, ja? If no, then we know what to do with people like you.” Okay, it wasn’t exactly like that. But at least this was the state prosecutor’s message: “Don’t worry that you won’t be able to pay the fine. You won’t need to, because I’m going to send you to prison.”

In a recent letter, Juergen tells me that he detects “a slight but distinct shift in the German media. It is as if something is holding them back from condemning homeschooling as easily as they used to…they are asking more and better questions.” He credits this to a growing perception by the public that there is something wrong with the state-run school system that is “less and less capable of providing a good education, any education at all.”

Juergen understands that the issue is ideological more than political or legal.

I’ve been thinking a lot about the implications of all this in our political culture. I’ve confronted politicians on county and federal levels with the situation of homeschooling families. All answers by politicians—educated, rational people—are pointing in the same direction. Germany is working hard in doing it “better” this time—a dictatorial state, where the authorities have all the power to tell the good from the bad, where the motto is mainstreaming (Gleichshaultung) and those who can’t agree with it are expatriated. To us, it isn’t just a question of law—rather, it’s a question of politics and ideology using law to achieve its aims.

At times, he has difficulty seeing how the German culture in which he grew up will change to embrace freedom for homeschoolers. “Nothing short of revolution could change the authorities’ attitude towards people behaving somewhat ‘outside the system’ (as they see it). But there is prayer—your prayer, prayer by brothers and sisters in Christ who feel strongly about His Kingdom to come in the hearts of the little ones.”

And because of that prayer, Juergen seems ever hopeful. He recalls Isaiah 8:12–13: “Do not call conspiracy everything that these people call conspiracy; do not fear what they fear, and do not dread it. The Lord Almighty is the one you are to fear, he is the one you are to dread” (New International Version).

As the Dudeks face a new trial after an appeals court overturned their 90-day prison sentence on the grounds of legal errors in the regional court’s ruling, Juergen writes that he and Rosemary are totally confident that God is protecting them. He quotes Isaiah 33:22: “The Lord is our judge; the Lord is our lawgiver; the Lord is our king; it is he who will save us” (New International Version).

Encouraging German Homeschoolers

There aren’t a lot of homeschoolers in Germany. In this country of nearly 100 million people, homeschoolers number merely in the hundreds, while in England, a much smaller nation, reports indicate over 100,000 homeschooled children. With a population three times the size of Germany’s,15 the United States has over 1.5 million homeschooled children, based on a conservative estimate by the U.S. Department of Education.16

Whenever I speak with German homeschoolers, they invariably tell me how much the support of U.S. homeschoolers means to them. To these homeschoolers, America is a light shining on a hill and our prayers, letters, phone calls, and other support are a lifeline to these isolated families. Some U.S. homeschoolers have even undertaken trips to provide encouragement to the Germans (see sidebar).

Samuel Adams, one of the United States’ Founders, said, “It does not take a majority to prevail, but rather an irate and tireless minority keen to set brushfires in the minds of the people.”

If U.S. homeschoolers continue to pray and encourage their German brothers and sisters, these brushfires in the minds of the German people will spread and result in positive change for a persecuted minority whose hope is fragile but firmly rooted in their faith in God and their desire to do what is best for their children.

Endotes

1. Home School Legal Defense Association, press release, August 1, 2008, http://www.hslda.org/hs/international/Germany/200808010.asp.

2. HSLDA, press release, November 18, 2008, http://www.hslda.org/hs/international/ Germany/200811180.asp.

3. Germany Basic Law Article 6 §2.

4. European Court of Human Rights, Fifth Section, Decision as to the Admissibility of Application no. 35504/03 by Fritz KONRAD and others against Germany. (2006) at 4. Summarizing the German Constitutional Court’s Ruling in the domestic case of Konrad v. Baden Wurttemberg (2003).

5. On December 24th, 2008, a German appeals court overturned Judge Becker’s ruling and his sentence. The reversal was on the grounds of technical legal errors and not because the appeals court disagreed with Judge Becker’s reasoning.

6. Encarta Dictionary English (North America) 2009.

7. European Convention on Human Rights Article 2 of Protocol No.1.

8. UN General Assembly, Third Session, UN Declaration of Human Rights (Paris, 1948).

9. Brian Ray, Homeschooling Grows Up (HSLDA, 2003).

10. Pierce v. Society of Sisters, 268 U.S. 510 (1925).

11. “Nazi Conspiracy & Aggression,” vol. 1, ch. 7, Nizkor Project, http://www.nizkor.org/hweb/imt/nca/nca-01/nca-01-07-means-44.html.

12. The Network for Educational Freedom, www.netzwerkbildungsfreiheit.org.

13. European Forum for Freedom in Education, www.effe-eu.org.

14. Kathy Sinnott, press release, July 17, 2008.

15. U.S. Census Bureau, “U.S. and World Population Clocks—POPClocks,” www.census.gov/main/www/popclock.html.

16. Stacey Bielick, “1.5 Million Homeschooled Students in the United States in 2007,” National Center for Education Statistics, 2008, http://nces.ed.gov/pubs2009/2009030.pdf.