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J. Michael Smith, President Michael P. Farris, Chairman
September, 2007

The Myth of Teacher Qualifications

by Chris Klicka, Senior Counsel for
Home School Legal Defense Association

“Some of the worst teachers I’ve ever seen are highly certified. Look at our public schools. They’re full of certified teachers. What kind of magic is that accomplishing? But I can take you to the best teachers I’ve ever seen, and most of them are uncertified.... We don’t have evidence at all that what we do in schools of education makes much difference in teacher competence.”1

—Dr. Donald Ericksen, UCLA

Most education officials publicly claim that teachers need special “qualifications” in order to be effective. As a result, public education organizations often promote legislation or an interpretation of the law which would require home school parents to have one of three qualifications: 1) a teacher certificate, 2) a college degree, or 3) pass a “teacher’s exam.” Although this seems reasonable on the surface, such requirements not only violate the right of parents to teach their children as guaranteed by the First and Fourteenth Amendments, but virtually all academic research documents that there is no positive correlation between teacher qualifications (especially teacher certification requirements) and student performance.

It also seems apparent that Americans in general are seeing through the “smoke screen” of teacher qualifications. On July 23, 1991, the results of a public opinion poll were released by the Washington-based Belden and Russonello public opinion research firm. It found that three out of four Americans disagreed with the notion that teacher certification requirements in public schools assure high-quality teachers. The poll also found that 71 percent do not believe that the lack of teacher certification in private schools means that their teachers are less qualified than public school teachers.2

Only the National Education Association and some of the other members of the educational establishment continue to defend teacher certification and high qualification standards for homeschoolers, in spite of the overwhelming research against the need for such teaching standards. Their vested interest in certified teachers may explain their blindness to the facts.

I have talked with hundreds of school officials who cannot understand how a “mere mother” with a high school diploma could possibly teach her own children. These officials literally take offense that parents would try to teach their children and actually think that they will do as well as teachers in the public school who have at least four years and sometimes seven years of higher education. Unfortunately, critics in the media have also believed this myth and will question the validity of home schooling by asking, “But are the parents qualified?” What is so laughable about this belief in teacher qualifications by public school authorities are the statistics which show the appalling decline in competency among certified public school teachers and the failure of the teacher colleges.

Since 1983, Home School Legal Defense Association (HSLDA) has been battling teacher qualifications for homeschool parents in the legal arena. I have fought hundreds of school districts which have misapplied the laws in states such as Alabama, Massachusetts, Pennsylvania, Ohio, Kansas, Maryland, Michigan, California, and South Carolina. These school districts often used the vagueness of the law to impose college degree or certification requirements on homeschool parents, which, if successful, would shut down over half of all homeschools. As of October 2006, the battles have been won in most of these states, either in the courts or in the legislature. Other states such as Iowa, North Dakota, Michigan, Florida, Virginia, and Washington applied more explicit laws requiring homeschoolers to be certified teachers. Most of these laws were finally defeated or repealed, but many families ended up in court in the process. For a period of 10 years, virtually every HSLDA member family that was discovered by a school district in North Dakota was taken to court for not being certified.

Homeschoolers need to remain constantly informed. For example, a few years ago the Kansas School Board Association made an unsuccessful attempt to get House Bill 2392 passed which would have required homeschoolers to be certified.3 Homeschoolers, as a result of these continuing attacks by school officials, lobbyists, and the media, need to be familiar with the statistics in this report in order to expose the “myth of teacher qualifications” so that no qualifications will be placed on homeschool parents.

This report summarizes research and opinions of professional educators, confirming the absence of a positive correlation between teacher qualifications and student performance. There is also a clear trend in the legislatures and the courts away from enacting or enforcing certification and other teaching standards to restrict homeschoolers.

Research and Researchers Which Expose the Myth of Teacher Qualifications

One of the most significant studies in this area was performed by Dr. Eric Hanushek of the University of Rochester, who surveyed the results of 113 studies on the impact of teachers’ qualifications on their students’ academic achievement. Eighty-five percent of the studies found no positive correlation between the educational performance of the students and the teacher’s educational background. Although 7 percent of the studies did find a positive correlation, 5 percent found a negative impact.4 Those who push for legislation requiring certain teacher qualifications for homeschoolers have no research to support the necessity of such standards. The results of these 113 studies are certainly an indictment on proponents of certain teacher standards for homeschoolers. Higher teacher qualification does not make better students.

Dr. Sam Peavey, professor emeritus of the School of Education at the University of Louisville, earned advance education degrees from Harvard (Master of Arts) and Columbia (Doctor of Education) and was involved in the preparation of thousands of prospective teachers for state certification. He has served on numerous committees and commissions dealing with the accreditation of schools and colleges. On September 30, 1988, Dr. Peavey testified before the Compulsory Education Study Committee of the Iowa Legislature on the subject of teacher qualifications, citing numerous studies. He stated:

May I say that I have spent a long career in developing and administering programs for teacher certification. I wish I could tell you that those thousands of certificates contributed significantly to the quality of children’s learning, but I cannot.... After fifty years of research, we have found no significant correlation between the requirements for teacher certification and the quality of student achievement.

Later in his testimony, Dr. Peavey explained that he has found only one valid way of identifying a good teacher:

However, in spite of years of frustration, I am pleased to report to you there has been discovered one valid, legal, honest, professional, common sense way to identify a good teacher. As far as I know there is only one way, and it is about time for legislators to recognize it and write it into school law. It involves a simple process. Step one is to stop looking at the teachers and start looking at the students. Step two is to determine how well students are learning what they are supposed to be learning. The quality of learning provides the only valid measure of the quality of teaching we have yet discovered [emphasis added].

Dr. Peavey concluded his testimony with practical examples of excellent student achievement results by students who were being taught by their parents, most without degrees or certificates. He explained that many studies demonstrate that homeschooled children “commonly score a year or more above their peers in regular schools on standard measures of achievement.”5

Another expert, Dr, Donald Ericksen, professor of education for the University of California at Los Angeles, stated in a recent interview:

Some of the worst teachers I’ve ever seen are highly certified. Look at our public schools. They’re full of certified teachers. What kind of magic is that accomplishing? But I can take you to the best teachers I’ve ever seen, and most of them are uncertified.... We don’t have evidence at all that what we do in schools of education makes much difference in teacher competence [emphasis added].6

In a well-known case before the Michigan Supreme Court concerning a Christian school’s challenge to the state’s teacher certification requirement, Dr. Ericksen testified as an expert witness on teacher certification. There he explained that extensive research has established that no significant correlation exists between certification (or teacher qualifications) and student learning, and that student testing is a far superior method of determining teacher effectiveness. Dr. Lanier, an expert who testified on the side of the state in favor of teacher certification, admitted under oath that she was unaware of any verifiable evidence establishing any correlation between teacher certification requirements and student learning or teacher competence.7

Two education researchers, R. W. Heath and M. A. Nielson surveyed 42 studies of “competency-based” teacher education. Their findings were that no empirical evidence exists to establish a positive relation between those programs and student achievement.8

Four other education researchers, L. D. Freeman, R. E. Flodan, R. Howsan, and D. C. Corrigan, did separate studies in the effectiveness of teacher certification requirements. They all concluded that there is no significant relation between teacher certification and student performance in the classroom.9

The 1990 Science Report Card surveyed almost 20,000 students in grades four, eight, and 12. The survey demonstrates that there is no relationship between the science achievement of students and the certification level or advanced degrees of their teachers. For instance, eighth-graders taught by teachers who had finished six or more college physics courses had virtually the same proficiency as those teachers who had no courses in physics.10

C. Emily Feistritzer, director of the private National Center for Education Information, claimed that she does not know “of a single study that says because a teacher has gone through this or that program, he or she is a better teacher.” Supporters of teacher training programs “argue eloquently that teachers need to be grounded in all of these things, but there has yet to be a study that shows that in fact this is the case.”11

In July 1999, the Thomas Fordham Foundation published a study entitled; “Better Teachers, Better Schools,” a 250-page study edited by Chester Finn & Marci Kanstoroom. This study report was broken into several sections including, “Teacher Licensing and Student Achievement.” The researchers employed data from the National Educational Longitudinal Study of 1988 (NELS), a nationally representative survey of about 24,000 eighth-grade students conducted in the spring of 1988. A subset of these students were resurveyed in 10th (1990) and 12th grades (1992).

The following two questions were the key questions of the study:

1) Do teachers with “standard” certification outperform teachers with alternative or probationary credentials in terms of the achievement of students?

2) Are different components of a state’s system of licensure systematically related to student achievement?

After careful comparison of the teachers’ certification or lack of certification with the students’ performance, their findings confirmed the results of the many other studies the teachers’ unions do not like to talk about. The authors explain:

Although teacher certification is pervasive, there is little rigorous evidence that it is systematically related to student achievement. Contrary to conventional wisdom, mathematics and science students who have teachers with emergency credentials do no worse than students whose teachers have standard teaching credentials, all else being equal. This result should, at the very least, cast doubt on assertions that standard certification should be required of all teachers. 12

The study also found that having a degree in education has no impact on student science test scores and, in mathematics, having a BA in education actually has a statistically negative impact on scores in math!

All the studies demonstrate that parents’ “hands-on” degree in homeschooling their own children is much more effective than spending all that time for a BA in education.

John Chubb, a fellow at the Brookings Institute (a liberal think tank), extensively studied various popular reforms including the push to professionalize teaching, toughen teacher certification standards, and implement more extensive teacher evaluation systems. As a result, he authored a book with Terry Moe, Politics, Markets, and America’s Schools on the subject of reform of education. Mr. Chubb found “no correlation between student achievement and any of the variables on which school reformers have been concentrating so much time, effort, and money.” He continues, “There is little reason to believe” that these actions will improve student achievement and “there is considerable reason to believe they will fail.”13

Dr. Brian Ray of the National Home Education Research Institute released a report entitled, A Nationwide Study of Home Education: Family Characteristics, Legal Matters, and Student Achievement. This was a study of over 2,000 homeschool families in all 50 states. The research revealed that there was no positive correlation between the state regulation of homeschools and the homeschooled students’ performance. The study compared homeschoolers in three groups of states representing various levels of regulation. Group 1 represented the most restrictive states, such as Michigan, which at the time of the study required homeschoolers to use certified teachers; Group 2 represented slightly less restrictive states including North Dakota; and Group 3 represented unregulated states, such as Texas and California, which have no teacher qualifications. Dr. Ray concluded:

No difference was found in the achievement scores of students between the three groups which represent various degrees of state regulation of home education.... It was found that students in all three regulation groups scored on the average at or above the 76th percentile in the three areas examined: total reading, total math, and total language. These findings in conjunction with others described in this section, do not support the idea that state regulation and compliance on the part of home education families assures successful student achievement.13

Furthermore, this same study demonstrated that only 13.9 percent of the mothers (who are the primary teachers) had ever been certified teachers. The study found that there was no difference in students’ total reading, total math, and total language scores based on the teacher certification status of their parents:

The findings of this study do not support the idea that parents need to be trained and certified teachers to assure successful academic achievement of their children.15

Whether the homeschool parent had a teaching certificate, a college degree, or a high school diploma or less, did not make any difference—all their children scored, on the average, in the 80th percentile.

This study has been confirmed by two other studies of the qualifications of homeschool parents. Dr. J. F. Jakestraw surveyed the student performance of homeschoolers in Alabama and reported:

This finding suggests that those children in Alabama whose parent-teachers are not certified to teach perform on standardized achievement tests as well as those whose parent-teachers are certified to teach. Therefore, it is concluded that there is no relationship between the certification status of the parent-teacher and the home-schooled children's performance on standardized achievement tests.16

Jon Wartes performed a similar study on homeschoolers over three years in the state of Washington and reached the same conclusion. 17

On the whole, homeschoolers’ achievements are ranked above average on standardized achievement tests as demonstrated by numerous studies. Dr. Ray and others have found that only 35 percent of teaching mothers have a college degree or higher, and yet their children score no higher on standardized achievement tests than those being taught by mothers without a college degree.

The Evidence is in: Teacher Qualifications Do Not Make Better Students

Nearly all existing research on teacher qualifications or state regulations demonstrates that they have no significant relation to student performance. In fact, teacher qualification requirements have no positive correlation with even teacher performance. In the end, as the Coleman Report (U.S. Office of Education, 1964) pointed out, families are the most important factors in determining a student’s academic performance.

Statutory Trend Lessening Teacher Qualification Requirements

The trend across the United States is to remove all teacher qualifications standards for homeschoolers. The emphasis seems to be on protecting parental rights and, in several states, focusing on student performance through an annual test or portfolio evaluation.

As of October 2006, 42 do not require homeschool parents to have any specific qualifications. Homeschoolers in these states can home school without proof of any particular educational qualifications. In fact, of the eight states that do have qualification requirements, seven of them require only a GED or high school diploma. The states in this category are North Carolina, Ohio, Pennsylvania, Georgia, South Carolina, Tennessee, West Virginia, and New Mexico. Of the remaining two states, only North Dakota presently requires the passage of a “teacher’s test”, college degree, or high school diploma if monitored by a certified teacher for two years.

South Carolina previously required a college degree or passage of a teacher’s examination. Michael Farris of HSLDA challenged the law, and on December 9, 1991, the South Carolina Supreme Court struck down the test, making a high school diploma the only qualification necessary for parents to home school.18 New Mexico required a Bachelor’s Degree, but this requirement was repealed due to efforts of the grassroots homeschoolers and HSLDA. Michigan’s statute, the last to require homeschool parents to have teaching certificates or use a person with a certificate to teach children, recently changed. On May 25, 1993, the Michigan Supreme Court struck down the teacher certification requirement as unconstitutional in People v. De]onge, a case I handled for eight years. Many of the other states which formerly had a law like Michigan’s also abandoned such teacher qualifications requirements.19

Major Cases on Teacher Qualifications for Home Schools and Private Schools

Below are summaries of several cases in various states that dealt with the issue of teacher qualifications and found teacher certification requirements or college degree requirements to be excessive or unconstitutional.

In New York, according to its compulsory attendance statute in section 3204, instruction “elsewhere” must be given by a “competent” teacher. In the case In re Franz the court interpreted “competent” to not mean “certified.”20 Furthermore, homeschool regulations adopted in June 1988 do not require homeschool parents to have any qualifications. Homeschool parents are “competent” as long as they file a notice of intent, quarterly reports of progress, and test results every other year beginning in third grade.

New Jersey law allows “equivalent instruction elsewhere than at school.”21 Regarding the interpretation of the word "equivalent," the New Jersey Supreme Court in the Massa case stated: “...perhaps the New Jersey Legislature intended the word equivalent to mean taught by a certified teacher elsewhere than at school. However, I believe there are teachers today teaching in various schools in New Jersey who are not certified.... Had the legislature intended such a requirement, it would have said so.”22

Ohio law requires homeschool teachers to be “qualified.”23 State Board of Education regulations define “qualified” as a GED or high school diploma.24 Prior to these regulations, in Ohio v. Whisner, the Ohio Supreme Court struck down Ohio’s Minimum Standards which required teacher certification, stating, “Equally difficult to imagine, is a state interest sufficiently substantial to sanction abrogation of appellants’ [parents’] liberty to direct the education of their children.”25 The Court pointed out that the state “did not attempt to justify [prove] its interest in enforcing the minimum standards [which included teacher certification requirements] as applied to non-public religious schools.”26

On May 25, 1993, Michigan’s teacher certification requirement for homeschools was struck down by the highest court of the state. In a four-to-three decision of the Michigan Supreme Court, four Justices found:

In sum, we conclude that the historical underpinnings of the First Amendment to the U.S. Constitution and the case law in support of it compels the conclusion that the imposition of the certification requirement upon the DeJonges violates the Free Exercise Clause. We so conclude because we find that the certification requirement is not essential to nor is it the least restrictive means of achieving the State's claimed interest. Thus, we reaffirm that sphere of inviolable conscience and belief which is the mark of a free people. We hold that the teacher certification requirement is an unconstitutional violation of the Free Exercise Clause of the First Amendment as applied to families whose religious convictions prohibit the use of certified instructors. Such families, therefore, are exempt from the dictates of the teacher certification requirements.27

Indiana presently allows homeschools under its law which exempts children from compulsory attendance if they are “provided with instruction equivalent to that given in public schools.”28 A federal court in the Mazenac case, when trying to interpret the word “equivalent,” stated: “ is now doubtful that the requirements of a formally licensed or certified teacher...would pass constitutional muster.”29 The Court would not interpret “equivalent instruction” as requiring certified teachers because of the constitutional problems involved.

In Massachusetts, “a child who is otherwise instructed in a manner approved in advance by the superintendent...” is exempt from attending public school.30 When establishing guidelines for approving homeschools, the Massachusetts Supreme Judicial Court stated, in the Charles case, that the superintendents or local public school committees could not require the parents to be certified or have college degrees. The Court said: “While we recognize that teachers in public schools must be certified, certification would not be appropriately required for parents under a home school proposal.... Nor must parents have college or advanced academic degrees.”31 In fact, the homeschool mother in this case, in whose favor the Court ruled, did not even have a high school diploma.32

In Kentucky, homeschools operate as private schools. When private schools were required to use certified teachers, even though the statute was unclear, the Kentucky Supreme Court, in the Rudasill case, ruled that teacher certification did not apply to private schools and could not be mandated.33

In Hawaii, according to its regulations, “parents teaching their children at home shall be deemed qualified instructors.”34 In other words, parents are qualified because they are parents. No certain degrees or diplomas are necessary for parents to be able to successfully educate their children.

In South Dakota, a child is allowed to be “otherwise provided with instruction.”35 The statute further explains that “the individuals [who give instruction] are not required to be certified.”

In North Dakota, Nebraska, and Iowa, teacher certification requirements were upheld by the courts in the Shaver, Faith Baptist, and Fellowship Baptist cases.36 In each of these cases no expert testimony or evidence was given to prove teacher certification was necessary or essential for children to be educated. In fact, the state could also not prove, with evidence, that teacher certification was the “least restrictive means” for children to be educated.

Furthermore, the legislatures in all three of these states have mooted these cases and vindicated homeschooling parents by repealing the teacher certification requirements. Nebraska and Iowa have created an option in their compulsory attendance statutes to allow parents to homeschool without any qualifications. North Dakota allows parents to pass a “teacher test” or produce a college degree in order to opt out of teacher certification.37

The Need For Teacher Qualifications is a Myth

Educational research does not indicate any positive correlation between teacher qualifications and student performance. Many courts have found teacher qualification requirements on home schoolers to be too excessive or not appropriate. The trend in state legislatures across the country indicates an abandonment of teacher qualification requirements for homeschool teachers. In fact, Americans, in general, are realizing that the necessity of teacher qualifications is a myth. The teachers’ unions and other members of the educational establishment make up the small minority still lobbying for teacher certification in order to protect their disintegrating monopoly on education.

Prepared by Chris Klicka, Senior Counsel for Home School Legal Defense Association

Copyright 2003, Christopher J. Klicka. Reprint permission is granted upon request.


1. “The ABC’s of Reform: Give Parents a Choice,” Insight, 24 September 1990, 13.

2. Carol Innerst, “Parents Prefer Private Schools,” Washington Times, 24 July 199.1, A3.

3. “Worst Home School Bill in the Nation Introduced in Kansas,” Home School Court Report, March/AprilI991, 5. Also “Kansas Teacher Certification Bill Shelved,” Home School Court Report, May/June 1991, 6.

4. Dr. Eric Hanushek, “The Impact of Differential Expenditures on School Performance,” Educational Researcher, May 1990.

5. Dr. Sam Peavey, testimony at a hearing before the Compulsory Education Study Committee of the Iowa Legislature, 30 September 1988. Dr. Peavey made similar statements in an interview with Insight, 24 September 1990, 13.

6. “The ABC’s of Reform: Give Parents a Choice,” Insight, 24 September 1990, 13.

7. Sheridan Road Baptist Church v. Department of Ed. , 396 N.W. 2d 373, 419 fn. 64 (1986).

8. “The Research Basis for Performance-Based Teacher Education,” Review of Educational Research, 44, 1974,463-484.

9. See W. R. Hazard, L.D. Freeman Legal Issues in Teacher Preparation and Certification, ERIC, Washington, D.C. 1977; R. E. Flodan, “Analogy and Credentialing,” Action in Teacher Education, Spring/Summer 1979; R. Howsam and D.C. Corrigan, Educating a Profession (Washington D.C., American Association of Colleges for Teacher Education, 1976).

10. “The 1990 Science Report Card: NAEP’s Assessment of Fourth, Eighth, and Twelfth Graders,” prepared by the Educational Testing Service for the National Center for Education Statistics, Office of Education Research and Improvement, U.S. Department of Education released March 1992.

11. “The ABC’s of Reform: Give Parents a Choice,” Insight, 24 September 1990, 13.

12. Chester Finn & Marci Kanstoroom, editors, “Better Teachers, Better Schools,” (Washington D.C.: Thomas Fordham Foundation, July 1999) p. 97. Quote is from a chapter by Dan Goldhaber and Dominic Brewer, “Teacher Licensing and Student Achievement.”

13. Ibid., 17. Also see John Chubb and Terry Moe, Politics, Markets, and American Schools (Washington, D.C.: Brookings Institution, 1990), 202-205.

14. Dr. Brian Ray, “A Nationwide Study of Home Education: Family Characteristics, Legal Matters, and Student Achievement” (Seattle: National Home Education Research Institute, 1990), 53-54.

15. Ibid., 53.

16. Dr. J. F. Jakestraw, “An Analysis of Home Schooling for Elementary School- age Children in Alabama,” Doctoral dissertation at the University of Alabama, 1987.

17. Jon Wartes, “Washington Home School Research Project,” Woodinville, Washington, 1987-1989.

18. “Home Schoolers Win EEE Case,” Home School Court Report, January/February 1992, 1; Lawrence v. South Carolina Board of Education, 412 S.E.- 2d 394 (1991).

19. See, e.g., Florida, F.S.A.§ 232.02 (4) (1982), and Florida Admin.Reg.6A- 1.951 (1974); New Mexico, N.M.S.A.§ 22-10-3 (1981); Virginia, Virginia Code § 22.1-254 (1980); Washington, R.C.W.§ 28A.27.010 (1980); Iowa Code Ann. section 299.1 (1988); North Dakota: Century Code section 15-34.1-04 (1987).

20. In re Franz, 55 A 2d 424, 427 (1977).

21. New Jersey Statutes Annotated § 18A:38-25.

22. New Jersey v. Massa, 231 A.2d 252,256 (1967).

23. Ohio Rev. Code Ann. § 3321.04(A)(2).

24. See Ohio State Board of Education Administrative Code Chapter 3301-34.

25. Ohio v. Whisner, 47 Ohio St.2d 181, at 214 (1976), 351 N.E. 2d 750.

26. Ibid., at 217.

27. Michigan v. Delonge, 501 N.W. 2d 127 at 144 (Mich. 1993)

28. Ann. lnd. Code § 20-8.1-3-34.

29. Mazenac v. North ]udson-San Pierre School Corporation, 614 F.Supp. 1152, 1160 (1985).

30. Ann. Law of Mass. ch. 76, §1.

31. Care and Protection of Charles, 504 N.E.2d 592,602 (Mass. 1987).

32. Ibid., 504 N.E.2d at 594, ftn. 2.

33. Kentucky State Board v. Rudasill 589 S. W .2d 877, 884 (1977).

34. Dept. of Ed. Regs. 4140.2(D)(2).

35. S.D. Cod. Laws Ann. §13-27-3.

36. See North Dakota v. Shaver 294 N.W. 2d 883 (1980), Nebraska v. Faith Baptist Church, 301 N.W. 2d 571 (1981), and Fellowship Baptist Church v. Benton, 815 F.2d 485 (1987).

37. See Revised Stat. of Nebraska §79-1701(3); N.D. Century Code §15-34.1-03; and Iowa H.F. 455(1991).