cost of educating a child in public school" (Wornsop, 1991, p. 259).
Over time, proponents of a voucher-based system of financing education have offered various arguments to support their position, the most frequent being that the quality of education would improve across all levels as schools are forced to compete with one another for students. In Friedman's words, "Parents could express their views about schools directly by withdrawing their children from one school and sending them to another" (Wornsop, 1991, p. 260). In such a system, governmental intrusion into the free-market education process could effectively be limited to ensuring that each school, public or nonpublic, met certain minimum standards.
Opponents of voucher systems return principally to the argument that government funds which find their way into the hands of religious schools violate the separation of church and state as expressed in the First Amendment. However, this argument was dealt with by the U.S. Supreme Court in 1971, in its ruling in the case of Lemon v. Kurtzman, when it created a three-part test which can be used to determine the constitutionality of state or federal laws which, to any extent, benefit parochial schools. Any such legislation must: 1) have a secular purpose; 2) have a primary effect that neither advances or inhibits religion; and 3) not lead to excessive entanglement between church and state (Jensen, 1983, p. 158). To this end the Court
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