Liberal proceduralism and religious orthodoxy have long battled across a ra
nge of controversies in U.S. education policy. An important setting for the
se controversies has been the promulgation by courts in recent decades of a
robust notion of students' rights. A victory for liberal proceduralism, st
udents' rights has in turn contributed greatly to a religious orthodox back
lash against public schooling manifest along a number of fronts, such as su
pport for vouchers, home schooling, and other withdrawal initiatives. This
article examines the ideological sources of this dynamic and whether libera
lism in general is able to meet the resulting challenge to its core ideals.