The Michigan Constitution of 1963, Article VIII, Section 1, states the following: "Religion, morality and knowledge being necessary to good government and the happiness of mankind, schools and the means of education shall forever be encouraged."50 In adopting this language–which sprang from the 1787 Northwest Ordinance–the people asserted that education is vital to our society and that knowledge, morality, and religion are necessary elements of that education.

The very same Constitution, however, and also the U. S. Constitution, place limits on the extent to which the government can support religious activities and organizations. This situation has created a tension between various visions of church and state separation and has shaped the current Michigan Constitutional provision regarding educational options for parents and students, especially with respect to nonpublic schools.