Oregon's Hillsboro School District has a Homeschooling Partnership program that, among other things, reimburses homeschooling parents for educational materials. However, the district will not reimburse parents for curricular materials that are embedded with a religious perspective. A homeschooling parent filed suit this week in an Oregon federal district court challenging this policy. The complaint (full text) in Bulzan v. Hillsboro School District, (D OR, filed 9/22/2026), contends that the district's refusal to reimburse plaintiff for Christian centered curricular materials violates plaintiff's rights under the 1st and 14th Amendments. The complaint alleges in part:
83. Through HSDHP, the District reimburses materials and experiences that promote a wide range of worldviews, including instruction that contradicts Christian beliefs and instruction with other spiritual themes....
130. District and HSDHP staff repeatedly declined Mrs. Bulzan’s reimbursement based only on the religious character of her homeschooling curriculum....
212. For Mrs. Bulzan, government school is premised on assumptions that are antithetical to her faith, and thus a government-school curriculum cannot educate her children consistent with her religious beliefs....
246. ... States cannot “discriminate[] against otherwise eligible recipients by disqualifying them from a public benefit” based on “religious character.” Trinity Lutheran, 582 U.S. at 462.
247. ... Oregon does not have to subsidize homeschool materials, but once it “decides to do so, it cannot disqualify some [homeschool materials] solely because they are religious.”...
271. Because Defendants substantially interfered with Mrs. Bulzan’s religious upbringing of her children—an “unacceptable” burden on religious exercise—Defendants’ actions receive strict scrutiny regardless of whether the policy is neutral and generally applicable....
288. Mrs. Bulzan’s right to direct her children’s education and upbringing includes the right to homeschool, and specifically the right to use religious instruction in her homeschool....
307. Defendants’ actions implicate—and violate—the First Amendment because they put “restraints on the way” that Mrs. Bulzan can speak by refusing to provide otherwise available funds for that speech,...
322. Where, as here, the government’s differential treatment is based on religion, the Equal Protection Clause demands strict scrutiny....
ADF issued a press release announcing the filing of the lawsuit.
