Washington Student Teacher Policies

Harrison v. Gregoire
Institute for Justice Challenged the State of Washington’s Discriminatory Student Teacher Policies

In September 2002, IJ filed a lawsuit on behalf of Carolyn Harrison, a student at the University of Washington, Tacoma, and Donnell Rene Penhallurick, a student at Eastern Washington University, challenging the universities’ practice of forbidding teacher degree candidates from student-teaching in religious schools.  The policies were triggered by two Washington state attorney general opinions in 1995 and 2000 that concluded that allowing public university students to student-teach in religious schools would violate the state constitution’s Blaine Amendment—a provision grounded in anti-Catholic and anti-immigrant animus and a favorite legal tool of school choice opponents.

The State promptly changed its policy to allow Harrison to intern at Bellarmine Preparatory School, a Jesuit school in Tacoma, to gain experience for an administrative credential.  However, Eastern Washington University claimed that it discriminated not just against religious schools, but all private schools, and the Thurston County Superior Court denied an injunction to Penhallurick that would have allowed her to student-teach at a Seventh-day Adventist school in Moses Lake.

Meanwhile, the State no longer justifies its policy under the Blaine Amendment.  Instead, it contends that its universities either deny student-teaching placements in all private schools, secular or religious, or allow them in both.  In light of the State’s new interpretation, IJ dismissed its lawsuit.

Essential Background


Backgrounder: The Next Step for School Choice: Removing State Constitutional Obstacles

Client Photo - none available

Client Video - none available

Latest Release: Institute For Justice Dismisses Student Teacher Lawsuit (April 24, 2003)

Legal Briefs and Decisions

Launch Release: IJ Launches School Choice Offensive With Nation’s First Choice Lawsuit After U.S. Supreme Court Victory (September 18, 2002)

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Case Timeline

Lawsuit Filed:


September 24, 2002

Court Filed:


Thurston County Superior Court



April 24, 2003: IJ dismissed lawsuit after Washington state abandoned its Blaine Amendment defense



Case Completed

Additional Releases

Maps, Charts and Facts

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