## Facts

- Iowa required children of compulsory-attendance age to attend school, either public school or qualifying nonpublic instruction.
- Iowa regulated nonpublic schools through requirements including teacher certification and reporting obligations (e.g., attendance records, teachers’ names, and books used).
- Iowa law also permitted compliance through “equivalent instruction by a certified teacher elsewhere,” but the statute did not define “equivalent instruction” at the time of suit.
- Fundamentalist Baptist churches operated church schools as religious ministries and objected on religious grounds to (a) state teacher-certification requirements and (b) state reporting and oversight measures.
- Plaintiffs (churches, church officials, teachers, parents, and students) brought constitutional challenges to Iowa’s compulsory education and nonpublic-school regulatory scheme, principally under the Free Exercise Clause.
- The district court upheld most challenged requirements but held the undefined statutory phrase “equivalent instruction” unconstitutionally vague.
- While the appeal was pending, Iowa adopted administrative “Equivalent Instruction Standards” specifying minimum curriculum requirements for grades one through eight.

## Issues

1. Whether Iowa’s teacher-certification and reporting requirements for nonpublic religious schools violate the Free Exercise Clause as applied to plaintiffs’ church schools.
2. Whether the statutory option of “equivalent instruction by a certified teacher elsewhere,” without further definition, is unconstitutionally vague.
3. Whether newly adopted administrative standards defining “equivalent instruction” affect the vagueness analysis on appeal.

## Decision

- The Eighth Circuit affirmed the district court’s rejection of plaintiffs’ broad Free Exercise challenge to Iowa’s compulsory attendance and nonpublic-school regulatory requirements, including teacher certification and reporting.
- The court held the challenged requirements were neutral and generally applicable measures directed at secular educational adequacy rather than religious doctrine.
- The court recognized Iowa’s interest in ensuring a minimum level of secular education for children as exceptionally strong and found the regulatory means reasonably related to that interest.
- On the vagueness question, the court did not definitively decide whether “equivalent instruction” was unconstitutional as originally enacted.
- The court remanded the vagueness issue to the district court to reconsider the statute in light of Iowa’s newly promulgated “Equivalent Instruction Standards.”

## Legal Principles

- Neutral, generally applicable education regulations that incidentally burden religious practice may be upheld when they serve a compelling or strongly important state interest and are reasonably related to achieving that interest.
- The state may require teacher qualification measures (including certification) and basic reporting/recordkeeping for nonpublic schools as part of enforcing compulsory education, so long as the regulations address secular educational standards and do not target religion.
- A law is unconstitutionally vague if it fails to provide fair notice of what is required or prohibited and fails to supply sufficiently definite standards to guide enforcement.
- When intervening administrative regulations provide concrete standards for an otherwise indeterminate statutory term, courts may reassess vagueness in light of the clarified regulatory framework.

## Conclusion

The Eighth Circuit upheld Iowa’s certification and reporting requirements for nonpublic religious schools against Free Exercise objections, finding them neutral regulations serving the state’s strong interest in minimum secular education, and remanded the “equivalent instruction” vagueness issue for reconsideration after Iowa issued curriculum-based standards defining that term.


Fellowship Baptist Church v. Benton, 815 F.2d 485 (8th Cir. 1987)