Since at least 1939, the state of Michigan has provided indirect support for private schools for auxiliary functions such as transportation, testing, health, and special services for handicapped children.43 Even prior to this time, and as early as 1921, some "shared time" classes were held involving both private and government school students and this continued until at least 1970.44 Starting in 1929, however, the state maintained a statutory prohibition on direct support for sectarian schools. 45

Although the Michigan constitution declares that "[r]eligion, morality and knowledge [are] necessary to good government,"46 it also, along with the U. S. Constitution, places limits on the extent to which government can support religious activities and organizations. This situation has created tension between various legal interpretations of "church and state separation" issues and has shaped the current Michigan constitutional provision regarding educational options for parents and students, especially with respect to private schools.