the state. The Arizona program survived a court challenge, ostensibly because tuition grants could go to religious schools. Greater Opportunities for Access to Learning is the Georgia program that offers a state income tax credit to donors of scholarships to private schools. Representative David Casas passed school choice legislation in Georgia. About 1.8 million children were home educated in 2012. In 2014 a lawsuit sought to challenge the legality of the Florida voucher program. In 2015, 14 cities had 30% or more of their students in charter schools, led by New Orleans, with 93% , 47 California school districts and 10,000 students participated in District of Choice, serving five percent of school districts and 0.2 percent of students. In the 2020 Espinoza v. Montana Department of Revenue case, the Supreme Court ruled that states could not restrict voucher programs from religious schools simply because the school was run by a religious organization. The Court further ruled in Carson v. Makin that states could not restrict the use of vouchers against any secular private school as long as the parents had a choice of school, as this would violate the Free Exercise Clause. By 2021 school choice students numbered 621,000, up from 200,000 in 2011. The next expansion was driven by pandemic-related dissatisfaction with public school policies and curricula. While many European school systems reopened in spring 2020, American public schools generally remained closed until the fall of 2021. For the 2020-2021 school year, public school enrollment fell by 3 percent. Private and charter schools grew an estimated 7 percent. 18 states either initiated school-choice programs or expanded offerings, making 3.6 million American students eligible for school choice and/or homeschool support programs. Several states expanded eligibility to include middle-class children. Also in Florida directed ~$200 million to increased low-income scholarships, while raising the income cap to $100,000, to reach an estimated 60,000 more students. In June 2021 New Hampshire established ESAs, with an income cap of $79,500. By November, New Hampshire 1,600 students had applied. In 2018-19 in West Virginia, teachers fought a charter expansion, twice launching strikes. In 2020 Republicans won a state legislative supermajority and offered ESAs to students of all incomes. In 2022 Alabama increased scholarship funding by 50%, to $30B. South Dakota expanded tax-credit scholarships. As of May 2022, 72% of US school parents favored vouchers, 76% supported ESAs, and 71% favored charter schools in the United