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Neither wants to give parents the freedom of choice that a voucher programme would provide.
Utahns have a ballot initiative on whether to accept the country's first statewide school voucher programme.
But the voucher programme may be succeeding where judicial fiat failed.
So, after the Cleveland voucher programme was set up, Mr Brennan decided to start his own schools.
The budget expands the private school voucher programme, which provides state subsidies for students to attend private schools, including religious ones.
The National Education Association, America's largest teachers' union, said that Edgewood could be a model for other urban school districts.Then its voucher programme started.
In 2002 the court held that Ohio's voucher programme, which overwhelmingly paid for students to attend religious schools, did not violate the establishment clause.
Studies of programmes elsewhere in the country suggest bigger improvements.The voucher programme may also be having the incidental effect of promoting racial integration.
The South has been sluggish when it comes to vouchers for students at awful public schools to use at private schools, though Florida has a voucher programme.
The voucher programme was subject to all sorts of restrictions when it was started in 1990, with only 1% of schoolchildren eligible and religious schools excluded.
One school, Messmer High, has eliminated the gap in test scores between blacks and whites.The voucher programme is also stimulating an array of new choices.
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com