District: Bible Course Doesn’t Count toward Homeschool Requirements

When a New York official recently asked a homeschool mom to clarify her thematic approach to teaching a specific course, he was trespassing on her fundamental freedoms.

HSLDA quickly intervened. We spared the family having to make unnecessary adjustments to their homeschool paperwork, while defending their right to teach their children according to their convictions.

“Our legal team is well-versed in defending against government overreach,” noted Ralph Rodriguez, HSLDA associate attorney. “But this situation dealt with so much more than how to file certain forms or what information the law requires—though that certainly played a part. The case actually touched on one of the core reasons many families choose to homeschool.”

A Matter of Faith

The issue began with a simple administrative request. Last autumn an official at a public school district near New York City contacted a member family to inquire about the first quarterly homeschool report they’d submitted for the 2025-2026 school year.

In these reports, homeschooling families are required to show the progress their students are making toward learning required subjects (the list is extensive) and compiling the requisite hours of instruction.

The official asked about a specific class the parent had listed which is not among the subjects mandated by state law—a course entitled “Understanding the Scriptures.” He insisted that, unless the class had been taught exclusively from a historical and literary perspective, it could not be counted toward the required hours of home instruction.

Put another way, he was saying that New York parents cannot count toward their homeschooling requirements any teaching that builds or supports religious faith.

Going Back to the Law

Understandably upset, the family contacted HSLDA for help. Rodriguez promptly communicated with the public school district. He explained that the official’s objection to the Bible studies course was mistaken for several reasons.

The official’s first error dealt with the administrative side of the issue.

“Unless there is something egregiously wrong with a homeschool report,” Rodriguez noted, “state law does not allow officials to reject it. If there’s something they don’t like, they can offer guidance for changes in subsequent reports.”

In this particular case, he added, there was nothing wrong with the parent’s report. The mom had noted in the document that her children had studied all the required subjects; the teaching on Scripture should have been viewed as akin to an elective.

Constitutional Rights

Finally, and most importantly, Rodriguez pointed out that raising objections to religious instruction violates fundamental constitutional guarantees. He supported this assertion by citing several US Supreme Court decisions, including the 2025 landmark ruling in Mahmoud v. Taylor.

“Although this case concerned curricular opt-outs, its reasoning applies equally here,” wrote Rodriguez. “A school official may not condition compliance with New York’s home instruction regulations on parents refraining from religious instruction or altering the religious nature of their chosen curriculum.”

The official quickly responded to Rodriguez, saying he planned to ask a team of administrators to review the information our attorney had provided. Meanwhile, our member family has heard nothing more about their quarterly report.