Oregon homeschooling program shuts out religious textbooks

Tessa Bulzan thought a program at Hillsboro School District in Hillsboro, Ore., could help cover the costs of her family’s homeschooling materials. The district said it would reimburse homeschooling parents up to $2,000 for resources that parents choose to purchase. But months after buying and using several Christian curricula, Bulzan learned she wouldn’t get any money back—all because she chose God-centered academic instruction.

Bulzan sued the school district in a federal court last week, contending its reimbursement denial discriminates against her religious beliefs. She argues the school district can’t bar her from a public benefit available to other families. Bulzan’s case highlights what some constitutional experts call a trend of government officials flouting the First Amendment and discriminating against religious families like hers.

According to the lawsuit, Bulzan gave up her corporate career at Nike to homeschool her children. She and her husband wanted to instill their Christian beliefs in their children by choosing religious homeschooling curricula. Bulzan felt that God called her to educate their children this way, even though she knew it would be a challenge for the family of seven to live only off her husband’s government salary.

Bulzan, whose children are currently between the ages of 10 months and 8 years, started homeschooling in 2025, when her oldest two children had just started second grade and kindergarten. Bulzan’s oldest daughter had previously been enrolled at a private Christian school, but Bulzan said its classes taught her child values that did not align with the family’s religious beliefs.

After Bulzan started homeschooling her kids, she enrolled them in Hillsboro School District’s Homeschool Partnership, part of the district’s online academy. The program offers a curriculum allowance of $2,000 per child per year, along with a tech stipend. It also offers in-person learning opportunities to help supplement home education. Under the program, families have the freedom to use their own “homeschool curriculum materials to provide individualized, parent-taught academic instruction at home,” its website states.

Homeschooling curriculum can be expensive, said Kate Anderson, an attorney at Alliance Defending Freedom, which represents Bulzan, adding that Bulzan felt like the program’s resources were a “godsend” for the family.

Ahead of the 2025 school year, a program administrator told Bulzan she could use any curriculum, even a religious one, according to the lawsuit. But the administrator did not mention that materials had to be nonreligious to qualify for reimbursement money.

Unaware of these requirements, Bulzan selected curricula from two Christian companies, Abeka and Classical Conversations, and enrolled her children in classes at a local Christian homeschooling co-op. Each of these offered the God-centered academic instruction Bulzan wanted for her children, the lawsuit says, and Bulzan felt the Abeka curriculum’s cursive program could help with one child’s dyslexia diagnosis.

After Bulzan enrolled her kids in Hillsboro’s program, she had little interaction with its officials. They provided next-to-no oversight, the lawsuit says. But when she went to submit her expenses for the end of the first semester, things took a turn.

District employees denied the reimbursement for both curricula and the co-op fees, citing the biblical worldview lessons the programs taught. Officials also said they couldn’t reimburse programs with Christian beliefs and themes. The district said that funding her materials would violate the U.S. Constitution’s establishment clause, as “public funds cannot be used for materials in which religious instruction is embedded in the core curriculum,” according to the lawsuit.

The district’s superintendent later doubled down on the decision, and a complaint process through the district’s various channels failed to bring any different results. WORLD reached out to Hillsboro School District for comment on the lawsuit, and a spokeswoman said the school can’t comment on pending litigation.

Without Hillsboro’s reimbursement, Bulzan will be unable to afford certain materials or extracurriculars, the lawsuit says. Bulzan said the district should reimburse her curriculum as it “more than satisfied Oregon’s academic standards—it exceeded them,” according to the lawsuit.

The Supreme Court has recently and repeatedly held that religious groups have the same access to publicly available benefits as nonreligious groups, Anderson said. In 2022, the high court found in Carson v. Makin that a public tuition-assistance program couldn’t exclude a private religious school.

“When the government sets out programs that are available to everyone, they can’t reject religious people, or in this case religious curriculum, simply because of its religious nature,” Anderson said. “That’s discrimination and a violation of the First Amendment.”

The government must treat all viewpoints equally, Anderson added. But Hillsboro has clearly favored other beliefs and worldviews over Bulzan’s, she said. It reimbursed a book for second graders about a boy mermaid who dresses like a girl and a kindergarten book detailing indigenous beliefs, the lawsuit says. But it rejected Bulzan’s reimbursement request solely because a “religious worldview was part of the backing for that curriculum,” Anderson said.

“There are a lot of homeschooling families that have been rejected from these kinds of programs,” Anderson added. “All families should have access to the same funding options so that they can educate their kids on equal footing.”

Families participating in other states’ programs have also faced religious denials, said Timothy Snowball, an attorney at Liberty Justice Center. In California, a group of parents appealed to the U.S. Supreme Court in August, asking it to uphold their right to purchase religious curriculum through a similar program at charter schools.

But the Constitution and Supreme Court precedent make it clear that Hillsboro is in the wrong, Snowball said. “Oregon is once again flouting that rule of law and deciding to try to discriminate against religious folks,” he said. “To me, this [case] looks like a slam dunk.”