United States Third Circuit

In a suit by parents who home-school their children seeking declaratory relief and a permanent injunction to prohibit the Commonwealth of Pennsylvania from requiring plaintiffs to comply with reporting and review requirements, summary judgment for defendants is affirmed where: 1) the challenged statute was a neutral law of general applicability, subject to rational basis review, and was constitutional as it rationally furthered legitimate state interests; 2) plaintiffs did not assert a valid "hybrid-rights" claim under which, as a potential violation of both free-exercise rights and the parental right to direct a child's education, the law might be subject to greater scrutiny; 3) plaintiffs' claims did not fall under the narrow exception of Wisconsin v. Yoder, 406 U.S. 205 (1972), requiring heightened scrutiny when parents challenge compulsory-education laws on religious grounds; and 4) having disposed of all federal claims, the court declined to exercise supplemental jurisdiction over state-law claims under the Religious Freedom Protection Act.

Appellate Information

• Argued 11/06/2007
• Decided 08/21/2008
• Published 08/21/2008

Judges

• Before:  SCIRICA, Chief Judge, AMBRO and JORDAN, Circuit Judges.

Court

• United States Third Circuit

Counsel

• For Appellant:
  
• Michael P. Farris, Esquire (Argued), James R. Mason, III, Esquire, Home School Legal Defense Association, Purcellville, VA, Attorneys for Appellants., Christopher C. Lund, Esquire, Dechert LLP Philadelphia, PA, Attorney for Amicus Curiae-Appellant, American Civil Liberties Union of Pennsylvania.


• For Appellees:
  
• Carl P. Beard, Jr., Esquire, Patrick J. Fanelli, Esquire, Andrews & Beard Altoona, PA, Attorneys for Appellee, Homer-Center School District., Christina Lane, Esquire, Andrews & Price, Pittsburgh, PA, Attorney for Appellees, Homer-Center School District, Titusville Area School District, Bristol Township School District, Franklin Regional School District, Stephen Vak, in his official capacity as Superintendent of Franklin Regional School District, Norwin School District, DuBois Area School District., Patricia K. Smith, Esquire, Knox McLaughlin Gornall & Sennett Erie, PA, Attorney for Appellees, Titusville Area School District, John D. Reagle, in his official capacity as Acting Superintendent of Titusville Area School District., Paul N. Lalley, Esquire (Argued), Levin Legal Group, P.C. Huntingdon Valley, PA, Attorney for Appellees, Bristol Township School District, Regina Cesario, in her official capacity as Superintendent of Bristol Township School District., Michael L. Brungo, Esquire, Ronald R. Lucas, Jr., Esquire, Alfred C. Maiello, Esquire, Maiello Brungo & Maiello, LLP, Pittsburgh, PA, Attorneys for Appellees, Norwin School District, Richard Watson, in his official capacity as Superintendent of Norwin School District, DuBois Area School District, Sharon Kirk, in her official capacity as Superintendent of DuBois Area School District., Ann G. St. Ledger, Esquire, Office of Attorney General of Pennsylvania Department of Education, Harrisburg, PA, Attorney for Amicus Curiae-Appellee, Pennsylvania Department of Education., Sean A. Fields, Esquire, Pennsylvania School Boards Association Mechanicsburg, PA, Attorney for Amicus Curiae-Appellee, Pennsylvania School Boards Association., Jeffrey I. Pasek, Esquire, Cozen & O'Connor, Philadelphia, PA, Attorney for Amicus Curiae-Appellee, Jewish Social Policy Action Network.