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School voucher programs attempt to bring market-based forces into public education by giving families choice in where their children attend school.  While the first voucher programs in the U.S. were introduced in rural areas-- generally in districts with no public schools-- most proponents of vouchers today propose them for low-performing urban districts.  Publicly-funded voucher programs haven’t been implemented widely in the U.S. thus far, but the most prominent examples of urban voucher programs have been operating in Milwaukee, Wisconsin, and Cleveland, Ohio, since the 1990’s. 

Nobel-Prize winning economist Milton Friedman was the first policymaker to suggest vouchers as a promising education reform.  Friedman suggested in his controversial 1955 publication, “The Role of Government in Education,” that, though the government has a responsibility to fund schooling, it should not actually administer school.  He proposed a voucher program similar to ones in operation today, in which parents receive a particular amount of money from the government and use it so their children may attend schools of their choice.  Friedman argued, however, that voucher programs like these should exist throughout the country—effectively that education should be entirely privatized.

Friedman’s ideas first took hold among Southern segregationists who hoped to use school choice ideals to avoid sending their children to integrated schools after the critical Brown v. Board of Education decision in 1954.  Though Friedman was anti-segregation, this perception that school vouchers could be used to prevent integration or could be implemented at the expense of minorities made national civil rights organizations wary of voucher programs until the 1980’s, when inner-city minority communities began to support school choice initiatives.  However, instrumental in the development of existing voucher programs have been alliances between African American communities and the Republican elite, for whom vouchers are generally not personally, but ideologically, appealing.

Most voucher supporters generally do not advocate for complete privatization of education, as Friedman suggested.  Rather, they argue that allowing parents of children in failing schools to exercise choice in where their children attend school will have two positive effects: (1) allowing low-income children access to better education in private schools, and (2) forcing traditional public schools to improve because they will have to compete with other schools for students and therefore for funding (Center for Education Reform, 2005). 

This argument came to the fore of national discourse on education reform in the early 1990’s as the first voucher program’s implementation in Milwaukee coincided with the publication of John Chubb and Terry Moe’s seminal work, Politics, Markets, and America’s Schools.  Chubb and Moe (1990) argued that bureaucratic governance of public schools was the culprit for America’s failing urban schools, and the authors advocated for greater autonomy for schools and choice for parents (Chubb, J., & Moe, T., 1991).  According to Elif Erison (2008), “Chubb and Moe (1990) reinvigorated the push for vouchers by adding to the economic rationale an institutional perspective that emphasizes the different constituencies of markets and politics” (Erison, 2008). 

The Milwaukee Parental Choice program predated Chubb and Moe’s work only slightly.  Its origination depended upon Wisconsin’s Republican Governor, Tommy Thompson, and a faction of the democratic state legislature, lead by Rep. Polly Williams (D) of Milwaukee (Economist, 1990).  Thompson introduced the idea of school choice in his 1989 State of the State address.  He said, “All of our children deserve equal opportunity in their education, and we must work together to implement a Wisconsin choice program.  Clearly, it cannot be done without the help of this legislature” (Thompson, 1989).  Thompson’s ally in the legislature, instrumental in the passage of the legislation creating the Parental Choice Program, despite the protests of the State Superintendent of Education, was Polly Williams, who argued that school choice programs would improve the lives of poor urban African American families.  The legislation allowed families whose incomes were 175% or less of federal poverty guidelines to receive a voucher of up to about $5,000 for tuition (Pietrowiak, D.M., & Jacobsen, D.C., 2001).  

Five years later, when the Cleveland Scholarship and Tutoring Program came to fruition, Cleveland’s public schools were not only failing to educate students, but they were also an abyss of financial mismanagement.  Robert Alt (1998) wrote,

“the District’s debt-to-revenue ratio was a crippling twenty-five percent . . .and a federal judge ordered the state superintendent of education to assume control of CCSD’s finances and administration . . . To address this crisis, the legislature chose to take drastic action: it enacted a school choice program” (Alt, 1998). 

According to the legislation, families could receive up to $2,250 to pay tuition at the private school of their choice.  When demand exceeded the number of vouchers available, priority was given to families whose incomes were less than 200% of federal poverty guidelines (Pietrowiak, D.M., & Jacobsen, D.C., 2001). 

The voucher programs in Milwaukee and Cleveland have been controversial.  Many opponents of vouchers criticize what they perceive to be vouchers’ negative effects on existing public schools, and suggest school reform efforts should be targeted at improving them.  The most significant barrier to the operation of school choice programs, however, was a challenge to the constitutionality of Cleveland’s voucher program. 

The Supreme Court decided in 2002, in Zelman v. Simmons-Harris, that the Cleveland school choice program did not violate the Establishment Clause of the First Amendment, which deals with the separation of religion and state. Chief Justice William Rehnquist wrote the opinion of the Court, and he developed the following criteria for school voucher programs, such that they do not violate the Establishment Clause: (a) voucher programs must serve secular purposes; (b) voucher programs can only provide indirect aid to religious schools; (c) the benefits of a school choice program must be made available to a broad group of beneficiaries; (d) a school voucher program can’t be set up to favor religious options over secular options; and (e) states must ensure that parents have adequate nonreligious options (Gryphon, 2003). 

According to Rehnquist, if a school choice program allows families to make “true private choices” of both religious and secular schools, then it is constitutional (Zelman v. Simmons-Harris, 2002).  The case allowed the Milwaukee and Cleveland programs to continue permitting parents to use vouchers at parochial schools.  According to a Rethinking Schools report, 96% of students participating in Cleveland’s school choice program attended religious schools, as did roughly two-thirds of students in Milwaukee’s Parental Choice program (Charney, 2007). 

Though voucher proponents anticipated accelerated growth of voucher programs following Zelman, programs like the ones in Milwauekee and Cleveland have not replicated on the scale their proponents expected and hoped.  Instead, since Zelman we’ve seen the introduction of more vouchers for special groups, such as special needs students, whose parents have traditionally been politically active.  There are two major reasons for this: (1) Zelman simply confirmed the constitutionality of using publicly-funded vouchers at parochial schools, which was a prerequisite for the continued operation of the Cleveland and Milwaukee programs but not a recipe for the creation of further programs, and (2) Urban, low-income families, who were the primary recipients of vouchers in Milwaukee and Cleveland, are often difficult to mobilize politically, thus making the implementation of new voucher programs quite difficult. 

Presumably, more school voucher programs could exist and could include religious schools, but political conditions have prevented the creation of new programs.  Additionally, two provisions in state constitutions may limit the creation of more school choice programs: compelled-support provisions, which protect citizens from being compelled to support religious institutions with tax money, and Blaine Amendments, which prohibit states from funding sectarian education.  According to analysis from the National Center for the Study of Privatization in Education, sixteen states have provisions in their state constitutions that make them unreceptive to school choice programs (Kemerer, 2002). 

Whether we see the creation of more publicly-funded school voucher programs will be determined, therefore, by state constitutions as well as the results of evaluations of existing programs and the contemporary political climate and Presidential administration, whose support for vouchers is thus far ambiguous (Elliott, S., 2008). 

                                                                                                                                                        Works Cited:

Alt, R. (1998).  Cleveland’s school voucher program: The politics and the law.  On Principal, v6n1.  Ashbrook Center for Public Affairs.


(1990, August 4). Polly's plan. The Economist. 


Center for Education Reform, Just the Faq's--school choice. Retrieved from http://www.edreform.com/Fast_Facts/Ed_Reform_FAQs/?Just_the_FAQs_School_Choice


Charney, M. (2001). High court takes up vouchers. Rethinking Schools Online, Winter 2001/2002. Retrieved from http://www.rethinkingschools.org/special_reports/voucher_report/v_high162.shtml


Chubb, J., & Moe, T. (1990).  Politics, markets, and America’s schools.  Washington, D.C.: Brookings Institute.


Elliott, S. (2008, February 24). Ohio teachers: where is Obama on education? Dayton Daily News


Erisen, E (2008).  Exit and voice in a deregulated market: The case of universal school voucher system in Chile.  Paper presented at the annual meeting of the ISA’s 49th Annual Convention, Bridging Multiple Divides.  San Francisco, CA, March 26, 2008. 


Friedman, M. (1955).  The role of government in education.  In R.A. Solo, Ed. Economics and the public interest.  Rutgers University Press.


Gryphon, M. (2003). True private choice: a practical guide to school choice after Zelman v. Simmons-Harris. Cato Institute Policy Analysis, 466.


Kemerer, F.R. (2002). The U.s. supreme court’s decision in the cleveland voucher case: where to from here? . Columbia Teachers College National Center for the Study of Privatization in Education., Retrieved from http://www.ncspe.org/publications_files/538_OCCP51.pdf


Pietrowiak, D.M., & Jacobsen, D.C. (2001).  School vouchers: Publicly funded programs in Cleveland and Milwaukee.  Washington, D.C.: U.S. Government Accounting Office. 


Thompson, T. "State of the State" in Senate Journal 1989-90. ([Madison, Wis.]: The Senate, 1989-1990:30-38); Online facsimile at:  http://www.wisconsinhistory.org/turningpoints/search.asp?id=1520; Visited on: 11/18/2009   



Zelman v. Simmons-Harris, 536 U.S. 639 (2002).











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