Oregon Homeschool Mom Sues for Religious Discrimination

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Tessa Bulzan, a Christian mother of five who homeschools her two oldest children in Oregon, is suing the Hillsboro School District for discriminating against her choice to use religious educational materials for her children.

Tessa Bulzan, a Christian homeschool mom in Oregon, recently filed a lawsuit after public school officials denied her reimbursement for religious curriculum.

Homeschoolers in Oregon are eligible for reimbursements for educational expenses. Similar programs operate in other states around the country — including Arkansas, where homeschoolers may receive funding via Educational Freedom Accounts.

But in Oregon, public school officials have apparently provided reimbursements for secular curricula while refusing to reimburse for religious curricula. Attorneys at Alliance Defending Freedom (ADF) write:

“Tessa Bulzan homeschools her children because she believes that God calls her to do so, instilling her faith in her children through her chosen homeschooling materials and curricula.

“Hillsboro School District offers a Homeschooling Partnership that reimburses parents for educational materials the parents choose and offers in-person learning opportunities to supplement home instruction. The program’s representative told Bulzan that she could use any curriculum, including a religious one, so she chose a combination of Abeka and Classical Conversations for her homeschooled instruction and enrolled her children in classes through the Firmly Planted Hillsboro co-op. All three provide God-centered academic instruction.

“After enrollment, the school district had very little interaction with Bulzan, providing virtually no oversight for her instruction. When the homeschooled mother went to submit her expenses for reimbursement at the end of the first semester, however, district employees denied reimbursing any of the Abeka or Classical Conversation costs and any of the Firmly Planted Hillsboro co-op fees ‘due to the Christian and biblical worldview that is taught’ and the ‘Christian beliefs and themes [that] are integrated throughout core subject areas.'”

ADF says Bulzan appealed the denial, but the school district still refused. Finally, she filed a lawsuit against the district with help from ADF.

To put it plainly, public officials cannot exclude religious people or religious groups from government programs.

In 2017, the U.S. Supreme Court ruled that it is unconstitutional to withhold public benefits to a person or group because they are religious.

The lawsuit against Oregon’s Hillsboro School District makes this point very clearly.

Arkansas has enacted good laws over the years like the Religious Freedom Restoration Act that stop the government from discriminating against people because of their religious convictions. Laws like it should help prevent cases like the one in Oregon from happening here.

We appreciate our friends at Alliance Defending Freedom standing up for religious liberty and defending homeschoolers in court.

Articles appearing on this website are written with the aid of Family Council’s researchers and writers.

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Homeschool Surge Continues in Arkansas

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The number of homeschoolers in Arkansas has more than doubled over the past ten years and is on track to go even higher.

In 2016, there were 19,520 homeschoolers across the state. By 2023, homeschooling had surged to nearly 30,000 students. And now official reports from the Arkansas Department of Education show that 40,470 children filed as homeschoolers during the 2026 school year.

One reason for the recent surge in homeschooling may be the Educational Freedom Account (EFA) program that Arkansas established under the LEARNS Act in 2023.

The EFA program makes it possible for students to use public funds to pay for an education at a public or private school or at home. Thousands of homeschool students have taken advantage of the program and test scores show they are excelling.

Many families feel that public education has deteriorated over the years, and they don’t like the direction it is heading. For those families, the EFA program offers real alternatives that help their children succeed. That is part of the reason Family Council and its Education Alliance homeschool division have supported the EFA program.

The State of Arkansas seems to be getting more out of each education dollar invested in homeschooling through the EFA program than anywhere else. That’s good for everyone.

The number of homeschoolers in Arkansas has risen drastically over the past decade — but especially since 2023.

As more families make good use of the EFA program, we believe Arkansas’ homeschool numbers could go even higher in the coming school year.

Articles appearing on this website are written with the aid of Family Council’s researchers and writers.

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Here is Why Homeschoolers in the EFA Program Do Not Take the Same Assessments as Public School Students

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A candidate for Arkansas Senate recently published a video on Facebook supporting new testing restrictions on homeschoolers and private school students who receive Educational Freedom Account (EFA) funding.

Most Arkansans may be aware that the State created the EFA program in 2023, making it possible for students to use public funds to pay for an education at a public or private school or at home.

What some people do not seem to understand is that every student receiving EFA money must take a nationally recognized norm-referenced test, and Department of Education data shows Arkansas’ EFA students are outperforming their peers nationwide.

Over the past year, different public figures have called for more regulation of the EFA program.

For example, during committee testimony in April, some Arkansas lawmakers argued EFA students should take the same assessments as public school students.

Last week, Arkansas State Senate candidate Missy Wardlaw posted a Facebook video arguing the same thing, saying:

“If taxpayer dollars are paying for a child’s education, whether it be public, private, or homeschool through EFAs, every student should take the same assessment. That’s the only way to honestly measure academic growth, compare results fairly, and ensure taxpayers know their investment is producing results. If public money is being spent, then public accountability should come with it.”

Arkansans need to understand two important points about how the EFA program works and why EFA students do not take the same assessments as public school students:

First, imposing a one-size-fits-all assessment on students does not strengthen accountability for the EFA program.

The EFA program already contains tremendous transparency and accountability requirements.

Under state law and state rules, every student’s EFA spending is subject to strict approval processes at the Arkansas Department of Education.

Financial data shows 90% of EFA spending goes directly to school tuition and other core educational expenses. The other 10% goes to enrichment activities like PE, athletics, music, and art, or other co-curricular programs. The Arkansas Legislature has actually limited vendor fees and capped EFA spending on these types of programs.

In June, the State moved forward with a new set of administrative rules establishing even more complicated preapproval and reimbursement requirements for homeschoolers participating in the EFA program.

EFA students already have plenty of regulation and accountability. Forcing homeschoolers and private school students to take the same assessments as public school students would not increase that accountability or make the program better.

Second, requiring EFA students to take the same assessments as public school students could ultimately drive EFA students to use the same curriculum as public schools.

The EFA program is designed to help families give their children the education that is right for them.

Many families may feel trapped by failing public school systems or by one-size-fits-all approaches to education. For those families, the EFA program offers options that help them and their children thrive.

The public school assessments are designed to measure students’ mastery of the material taught in public schools. Forcing EFA students to use those assessments could drive them to use the public school curriculum as well.

That goes against the entire point of the EFA program.

Students in the Educational Freedom Account program are doing well, because the program gives them the freedom to pursue the education that is right for them. Arkansans need to understand what has made the EFA program successful, and lawmakers should oppose any effort to impose a one-size-fits-all approach to education on EFA students.

Articles appearing on this website are written with the aid of Family Council’s researchers and writers.

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