but is caused by external factors during early childhood. He anecdotally cites as evidence the life of actress Anne Heche, who was previously in a relationship with Ellen DeGeneres. Criticizing "the realities of judicial tyranny," Dobson has written that "[t]here is no issue today that is more significant to our culture than the defense of the family. Not even the war on terror eclipses it." Critics have stated that Dobson's views on homosexuality do not represent the mainstream views of the mental health community, with Dan Gilgoff referring to the positions of the American Psychiatric Association and the American Psychological Association on homosexuality. Views on schooling Focus on the Family supports private school vouchers and tax credits for religious schools. According to Focus on the Family website, Dobson believes that parents are ultimately responsible for their children's education, and encourages parents to visit their children's schools to ask questions and to join the PTA so that they may voice their opinions. Dobson opposes sex education curricula that are not abstinence-only. According to People for the American Way, Focus on the Family material has been used to challenge a book or curriculum taught in public schools. Critics, such as People for the American Way, allege that Focus on the Family encourages Christian teachers to establish prayer groups in public schools. Dobson supports student-led prayer in public schools, and believes that allowing student-led Christian prayer in schools does not violate the First Amendment to the United States Constitution. Views on discipline within the family In his book Dare to Discipline, Dobson advocates the spanking of children up to eight years old when they misbehave, but warns that "corporal punishment should not be a frequent occurrence" and that "discipline must not be harsh and destructive to the child's spirit." He warns against "harsh spanking" because "It is not necessary to beat the child into submission; a little bit of pain goes a long way for a young child. However, the spanking should be of sufficient magnitude to cause the child to cry genuinely." Dobson has called disciplining children to be a necessary but unpleasant part of raising children that should only be carried out by qualified parents: In his book The Strong-Willed Child, Dobson suggests that if authority is portrayed correctly to a child, the child will understand how to interact with other authority figures: In Dobson's opinion, parents must uphold their authority