 The territorial legislature had already passed a series of laws regulating who could teach and how often students could attend classes, and in April 1923 the Clark Bill imposed a per-student tax, forcing many schools to close when they could not (or would not) pay the tax.In the meantime, California politicians enacted the Parker Bill in August 1921, establishing extensive prerequisites for teacher certification and giving complete control over hiring, operations and curricula in the schools to the Superintendent of Public Education.Late in December 1922, sixteen Hawaiian schools banded together to file a lawsuit challenging the restrictions.