We respectfully dissent from the majority opinion. The decision of the Court of Appeals should be affirmed.
i
The present case requires this Court to examine the Free Exercise Clause and the cases that have *300interpreted it.1 In Employment Div, Dep’t of Human Resources v Smith, 494 US 872, 881; 110 S Ct 1595; 108 L Ed 2d 876 (1990), the Court held that the Free Exercise Clause does not relieve a person from complying with valid or neutral laws of general applicability simply because the law is contrary to the claimant’s religious practice. However, the Court noted:
The only decisions in which we have held that the First Amendment bars application of a neutral, generally applicable law to religiously motivated action have involved not the Free Exercise Clause alone, but the Free Exercise Clause in conjunction with other constitutional protections, such as . . . the right of parents, acknowledged in Pierce v Society of Sisters, 268 US 510 [45 S Ct 571; 69 L Ed 1070 (1925)] to direct the education of their children, see Wisconsin v Yoder, 406 US 205 [92 S Ct 1526; 32 L Ed 2d 15 (1972)].[2]
Thus, in the absence of a "hybrid situation”3 in which a claimant alleges a violation of the Free Exercise Clause and another, recognized constitutional protection, an exemption from compliance with the law will not be granted as long as the law is otherwise valid and generally applicable to all segments of society. As a result of Smith, constitutional challenges on the basis of the Free Exercise Clause alone are defeated, because successful constitutional challenges turn on the existence of another recognized constitutional right. The major*301ity’s conclusion that the teacher certification requirement violates the Free Exercise Clause and the DeJonges’ right to direct the education of their children is a significant expansion of Michigan law with which we disagree. In Pierce and Yoder, supra, the Court recognized parents’ rights to direct the religious education of their children. Today, the majority holds that parents have a fundamental constitutional right, when coupled with the Free Exercise Clause, to direct the secular education of their children, as well. The. majority’s conclusion, while not defensible under a Smith analysis, does not withstand careful examination even if one accepts the existence of a hybrid situation.
The claimants rely on Pierce, supra, and Meyer v Nebraska, 262 US 390; 43 S Ct 625; 67 L Ed 1042 (1923), as support for a fundamental right to direct the education of their children completely free of state regulation. However, Pierce and Meyer addressed the elimination of parental choice, while the present case deals with the regulation of it. In Murphy v Arkansas, 852 F2d 1039, 1043 (CA 8, 1988), the court concluded that "recognition of such a right would fly directly in the face of those cases in which the Supreme Court has recognized the broad power of the state to compel school attendance and regulate curriculum and teacher certification.”4
*302It is true that at trial, the DeJonges’ minister testified that his church teaches that children are given by God to parents, and that Scripture clearly teaches that the responsibility of educating children belongs to the parents. Michael McHugh, from the Church of Christian Liberty and Academy, testified that the curriculum prescribed by his organization to the DeJonge children included a heavy emphasis on character development through Bible study, which also permeates into the traditional subject-matter areas. It is true that Mark DeJonge testified that in contravention of their faith, the certification requirement makes the DeJonges responsible to the state, and not God, for their children’s education. This testimony, the majority argues, sufficiently establishes that the teacher certification requirement implicates directly the DeJonges’ right to direct the secular education of their children.
Pursuant to this finding, an examination of the DeJonges’ free exercise claim requires this Court to balance the respective interests of the parties. In Sherbert v Verner, 374 US 398, 403; 83 S Ct 1790; 10 L Ed 2d 965 (1963), the Court stated that in order for a state regulation that infringes on free exercise rights to remain valid, the regulation must be justified by a compelling state interest. The appropriate free exercise inquiry is whether government has placed a substantial burden on the observation of a religious belief or practice *303and, if so, whether a compelling governmental interest justifies the burden. Hernandez v Comm’r of Internal Revenue, 490 US 680; 109 S Ct 2136; 104 L Ed 2d 766 (1989); Hobbie v Unemployment Appeals Comm of Florida, 480 US 136; 107 S Ct 1046; 94 L Ed 2d 190 (1987); Thomas v Review Bd, 450 US 707; 101 S Ct 1425; 67 L Ed 2d 624 (1981); Yoder and Sherbert, supra; Dep’t of Social Services v Emmanuel Baptist Preschool, 434 Mich 380; 455 NW2d 1 (1990); Sheridan Rd Baptist Church v Dep’t of Ed, 426 Mich 462; 396 NW2d 373 (1986), cert den 481 US 1050 (1987). Under the "compelling interest test,” the court is required to conduct a four-part inquiry.5 First, the defendants must prove that they possess a sincerely held religious belief. Yoder, 406 US 215; Emmanuel Baptist, 434 Mich 392. Second, the defendants must prove that the state regulation imposes a burden on the free exercise of their belief. Tony & Susan Alamo Foundation v Secretary of Labor, 471 US 290, 303; 105 S Ct 1953; 85 L Ed 2d 278 (1985); United States v Lee, 455 US 252, 256-257; 102 S Ct 1051; 71 L Ed 2d 127 (1982); Emmanuel Baptist, 434 Mich 393.
Once the defendants successfully establish the first two parts of the test, the court will inquire whether the state possesses a compelling interest that justifies the burden imposed upon the defendants’ beliefs. Hobbie, 480 US 141-142; Emmanuel Baptist, 434 Mich 395. Once a compelling interest is clearly established, the majority would require the state to prove that the teacher certification requirement is the least restrictive means of regulation.*3046 We disagree. In United States v Lee, supra, the Court departed from the "least restrictive means” requirement. After concluding that the government’s interest in assuring mandatory and continuous participation in the social security system is "very high,”7 the Court stated that the "remaining inquiry is whether accommodating the Amish belief will unduly interfere with fulfillment of the governmental interest.”8 Although the Court declined to further define "undue interference,” surely it is a less burdensome standard than the "least restrictive means” requirement.9 Thus, in the present case, this Court should inquire whether accommodation of the DeJonges’ beliefs would unduly interfere with the fulfillment of the state’s interest in education.
The majority would apparently further require the regulation to be the least restrictive when compared with the other forty-nine states. Undoubtedly, we can survey similar regulations utilized in our sister states in order to determine the relative obtrusiveness of our requirements. Yet, the mere existence of less restrictive regulation in other states tells us little about that state’s success at achieving the compelling interest in universal education. Indeed, some states may have quality *305objectives that differ from those of Michigan. Regardless, we do not believe it is necessary for the state to establish that the certification requirement is the least restrictive means of achieving its compelling interest in education.
The majority would also require the state prove that "the means chosen be essential to further th[e] interest.”10 We disagree. In equal protection cases involving race discrimination, the regulation in question is presumed invalid and the court employs strict scrutiny, in which the court asks if the state has a compelling interest and if the means chosen are essential to further that interest.11 However, for purposes of the Free Exercise Clause, this equal protection inquiry is not a part of the compelling interest test adopted by this Court. Unlike the equal protection inquiry, there is no presumption of invalidity and the claimant bears the initial burden. By imposing such a substantial burden on the state, the majority’s compelling interest test is specifically designed to cause the state to fail.
n
A
Applying the compelling interest test to the present case, we reach several conclusions different from those of the majority. We agree with the majority that the DeJonges possess a sincerely *306held religious belief.12 There is sufficient evidence on the record for the trial judge to conclude that the DeJonges’ convictions and sincerity were beyond dispute. In order to meet the second part of the inquiry, the DeJonges must prove that the state regulation imposes a burden on the exercise of their belief. A burden may be found where a state "put[s] substantial pressure on an adherent to modify his behavior and to violate his beliefs . . . .” Thomas, 450 US 718. Stated in another manner, ''[t]he question is whether the 'affected individuals [would] be coerced by the Government’s action into violating their religious beliefs [or whether] governmental action [would] penalize religious activity by denying any person an equal share of the rights, benefits, and privileges enjoyed by other citizens.’ ” Emmanuel Baptist, 434 Mich 393, quoting Lyng v Northwest Indian Cemetery Protective Ass’n, 485 US 439, 449; 108 S Ct 1319; 99 L Ed 2d 534 (1988).
B
Because the DeJonges met their burden regarding the first two parts of the compelling interest test, the reviewing court must be satisfied that the state possesses a compelling interest that justifies the burden imposed upon the DeJonges’ religious beliefs. In Prince v Massachusetts, 321 US 158, 166; 64 S Ct 438; 88 L Ed 645 (1944), the Court indicated the relative importance of the state’s interest in the welfare of children.
[T]he family itself is not beyond regulation in the public interest, as against a claim of religious liberty. Reynolds v United States, 98 US 145 [25 L Ed 244 (1878)]; Davis v Beason, 133 US 333 [33 L *307Ed 637 (1890)]. And neither rights of religion nor rights of parenthood are beyond limitation. Acting to guard the general interest in youth’s well being, the state as parens patriae may restrict the parent’s control by requiring school attendance, regulating or prohibiting the child’s labor and in many other ways.
The majority concludes that "the state’s interest is simply the certification requirement of the private school act, not the general objectives of compulsory education. The interest the state pursues is the manner of education, not its goals.”13 We disagree.
We believe that the state possesses a compelling interest in education. The majority properly notes the importance of education to the vitality of our state and nation, and it is unnecessary to reiterate those sentiments.14 The statements expressed by the majority lead an objective reader to conclude that the state’s interest in this case is the universal education of school-age children, and not the certification requirement. The certification requirement is an effective means, chosen by the state to achieve its interest in the education of school-age children. In fact, the certification requirement ensures that educators possess a minimal level of .competency before they may take on the task of preparing our children for their future endeavors. As Justice Boyle noted in Sheridan Rd, 426 Mich 509-510:
The teacher certification requirements are essentially prophylactic in nature. Certification does not guarantee that a person will be an effective teacher, but it increases the probability that a teacher will be competent. Therefore, the certificá*308tion requirements help prevent children from being exposed to unqualified teachers. [Boyle, J., concurring.]
Furthermore, although correctly observing that the Court may not recharacterize the defendants’ beliefs, the majority offers no support for what is actually the crux of its argument — that is, that this Court has the authority to recharacterize the nature of the state’s interest as the "manner of education.”15 Nor, of course, is there any support in decisions from the United States Supreme Court for the even more remarkable proposition that the state’s interest is not in "ensuring that the goals of compulsory education are met, because the state does not contest that the DeJonges are succeeding at fulfilling such aims.”16 To conclude that the state is without authority to protect all of the children within its boundaries unless it can prove that a given parent is not satisfying the state’s interest is to radically alter the relationship between the Legislature and the Court. Such a result, it might be noted, would assuredly offend the Founding Fathers.
The majority, would require the state to prove that its compelling interest is "truly compelling, threatening the safety or welfare of the state in a clear or present manner.”17 However, such a requirement is untenable. West Virginia Bd of Ed v Barnette, 319 US 624; 63 S Ct 1178; 87 L Ed 1628 (1943), is not authority for holding that the Free Exercise Clause requires the state to prove that *309the parent’s right threatens the state in a clear and present manner.18 In Sherbert v Verner, 374 US 403, the Court utilized the "clear and present manner” language in an effort to categorize its prior decisions in which it rejected free exercise challenges to government regulation. "The conduct or actions so regulated have invariably posed some substantial threat to public safety, peace or order.”19 Simply because the Court in Sherbert used this language to categorize those decisions in which state regulation was upheld, it does not necessarily follow that in all cases thereafter a threat to the safety or welfare of the state is required in order for a free exercise challenge to be rejected. Most importantly, this Court has not expressly adopted a "clear and present manner” requirement in association with the compelling interest test, and such an expansion is unwarranted here.
*310C
Finally, this Court must inquire whether accommodating the DeJonges’ religious beliefs would unduly interfere with fulfillment of the state’s interest in education. The private, denominational, and parochial schools act20 provides a basic pronouncement regarding teachers’ qualifications. Pursuant to the act, a teacher must hold a "certificate such as would qualify him or her to teach in like grades of the public schools of the state . . . .”21 The express intent of the act is to institute qualifications for teachers that employ the same standard as that provided by the general school laws of the state.22 Thus, in order to ascertain the minimum qualifications for certification in nonpublic schools, it is essential to examine the requirements for certification in the public schools.
The Legislature charged the State Board of Education with the duty of determining the requirements and issuing all licenses and certificates for teachers.23 The majority asserts that Michigan "does not command a certification requirement for the great majority of its students, but only for those taught by their parents at home.”24 We disagree.
The Legislature has issued a directive to the various local school boards of the state. Because this directive implicates the qualifications for teachers in the public schools, it is applicable to the qualifications for teachers in nonpublic schools. See MCL 388.553; MSA 15.1923. The Legislature *311has expressly stated that local school boards shall not permit instruction by a teacher who does not possess a valid teaching certificate.25 If, in fact, such an individual is teaching within the district, the state board must be immediately notified.26 However, the certification requirement is not "absolute.” Subject to the availability of a certified teacher,27 a local school board may engage a noncertified instructor to teach computer science, a foreign language, mathematics, biology, chemistry, engineering, physics, or robotics to students in grades nine through twelve.28 The noncertified teacher must possess a bachelor’s degree, major in or possess a graduate degree in the field of specialization to be taught, and have two years of occupational experience in the field to be taught. If the instructor intends to teach for more than one year, then the instructor must pass a basic skills examination and a subject area examination. Thus, the certification requirement has not been abandoned for the majority of teachers, and the Legislature has added an element of flexibility to the requirement in order to attract qualified individuals to teach high school students specialized fields of study.
The State Board of Education also established a set of exceptions within which a person may be qualified to teach without a valid teacher’s certificate. Under the State Board of Education’s *312Teacher Certification Code,29 in addition to possessing a teaching certificate,30 a person with "vocational authorization”31 or a "special permit”32 is authorized to teach in the public schools.
The state board issues three types of special permits: full-year special permits,33 substitute permits,34 and emergency permits. Emergency permits are issued as follows:
*313In emergency situations and on recommendation of the superintendent of a local or intermediate school district, the state board may issue a permit for a candidate with reasonable qualifications if a candidate who meets the requirements for obtaining a substitute permit or a full-year permit is not available and if failure to authorize this emergency permit will deprive children of an education. The permit shall be issued for a specific period of time under emergency circumstancés. A labor dispute is not an emergency circumstance. [1989 AACS, R 390.1145.]
Amicus curiae State Board of Education submits that since January of 1987, it has adopted a uniform policy regarding emergency permits. Pursuant to this policy, candidates for a permit have "reasonable qualifications” if they possess a bachelor’s degree. Thus, upon a finding by the local school board that another instructor is "unavailable” and that failure to authorize the permit will result in the deprivation of education, any person who has earned a bachelor’s degree may obtain an emergency permit to teach.
Clearly, an element of flexibility and accommodation already exists within this statutory and administrative framework for teacher certification. Certification is required of teachers in the majority *314of circumstances. However, pursuant to statutory authority and the Teacher Certification Code, several exceptions exist in which uncertified persons may nonetheless be qualified as instructors. The requirements under these exceptions, while not particularly stringent, operate as the minimum qualifications a person must possess in order to teach. Any attempt to further reduce these minimum qualifications, or to allow parents without them nonetheless to teach their children, will increase the possibility that students will not be properly taught and thus not properly learn as much as they should, thereby causing the state to fail to achieve its compelling interest to educate.
Similarly, any alternative to the certification requirement, such as standardized testing, would fail to adequately ensure that the state’s interest is being pursued vigorously. In Sheridan Rd, 426 Mich 484, Chief Justice Williams concluded that standardized testing is not an acceptable alternative to teacher certification.
[Standardized testing] is an inadequate substitute because deficiencies in teaching would be discovered only after the damage has occurred. State v Shaver, 294 NW2d 883 (ND, 1980). Further, we are not persuaded that testing would guarantee less intrusion by the state into the functioning of the private schools.
Although the majority of our sister states have statutory authority permitting home schools, Michigan is not alone in requiring teacher certification. Alabama exempts a child from compulsory attendance if the child receives "instruct[ion] by a competent private tutor for the entire length of the school term in every scholastic year . . . .”35 *315However, a competent private tutor is a person who is certified.36 California also grants an exemption from compulsory attendance where the child is engaged in a structured tutoring program.37 Once again, the tutor must possess valid state certification. Finally, Kansas only exempts a child from compulsory attendance where the child attends a "private, denominational or parochial school.”38 In State v Lowry, 191 Kan 701; 383 P2d 962 (1963), the Kansas Supreme Court held that a home school is not the equivalent of a private, denominational, or parochial school. The court also held that home instruction does not meet the requirements of the compulsory school attendance laws. In re Sawyer, 234 Kan 436; 672 P2d 1093 (1983); State v Garber, 197 Kan 567; 419 P2d 896 (1966), app dis 389 US 51 (1967).
hi
We have examined the claims of the DeJonges and the state pursuant to the compelling interest test. After careful review and balancing of the respective interests, we have determined that the state possesses a compelling interest in the universal education of its children and that the certification requirement is an effective means of achieving this interest. Further, accommodation of the DeJonges’ religious beliefs would unduly interfere with the state’s fulfillment of its interest in education. Accordingly, the DeJonges’ convictions and the Court of Appeals decision should be affirmed.
Brickley and Boyle, JJ., concurred with Mallett, J._The majority’s assertion that this Court has long held that the constitution must be interpreted in light of the intent and understanding of its drafters seems to inject needlessly, and therefore gratuitously, the original intent debate into the present controversy. Given the lack of authority for the majority’s position, resort to the "Founding Fathers” suggests the substitution of doctrine for legal analysis.
Smith, 494 US 881.
Id. at 882.
The court in Murphy relied on Bd of Ed v Allen, 392 US 236, 245-247; 88 S Ct 1923; 20 L Ed 2d 1060 (1968), which stated:
Since Pierce, a substantial body of case law has confirmed the power of the States to insist that attendance at private schools, if it is to satisfy state compulsory-attendance laws, be at institutions which provide minimum hours of instruction, employ teachers of specified training, and cover prescribed subjects of instruction. Indeed, the State’s interest in assuring that these standards are being met has been considered a sufficient reason for refusing to accept instruction at home as *302compliance with compulsory education statutes. These cases were a sensible corollary of Pierce v Society of Sisters [supra]: if the State must satisfy its interest in secular education through the instrument of private schools, it has a proper interest in the manner in which those schools perform their secular educational function.
See also State v Faith Baptist Church, 207 Neb 802; 301 NW2d 571 (1981).
We have combined the first two steps of the compelling interest test as articulated by the majority. The claimant’s burden pursuant to the compelling interest test, as articulated by this dissent, is consistent with the approach taken in Sheridan Rd and Emmanuel Baptist, supra.
"Least restrictive means” is a requirement that evades an exacting definition. In Illinois State Bd of Elections v Socialist Workers Party, 440 US 173, 188-189; 99 S Ct 983; 59 L Ed 2d 230 (1979), Justice Blackmun, concurring, warned that we should exercise caution in the application of this elusive principle.
"[Ljeast drastic means” is a slippery slope . . . [, and a] judge would be unimaginative indeed if he could not come up with something a little less "drastic” or a little less "restrictive” in almost any situation, and thereby enable himself to vote to strike legislation down.
Id. at 259.
Id. (emphasis added).
See Tribe, American Constitutional Law (2d ed), § 14-13, p 1261.
Ante at 286, citing United States v Lee, 455 US 257-258.
See Palmore v Sidoti, 466 US 429, 432-433; 104 S Ct 1879; 80 L Ed 2d 421 (1984). "[Racial] classifications are subject to the most exacting scrutiny; to pass constitutional muster, they must be justified by a compelling governmental interest and they must be 'necessary . . . to the accomplishment’ of their legitimate purpose . . . .” See also McLaughlin v Florida, 379 US 184, 196; 85 S Ct 283; 13 L Ed 2d 222 (1964); Loving v Virginia, 388 US 1, 11; 87 S Ct 1817; 18 L Ed 2d 1010 (1967).
Ante at 281-283.
Ante at 290.
Ante at 288, n 43.
Ante at 290.
Ante at 290.
Ante at 286. If, in fact, this inquiry was a part of the compelling interest test, the conduct or actions being regulated would threaten the safety or welfare of the state.
The language excerpted by the majority and relied upon for this conclusion is dicta. Barnette is arguably a free speech case that marginally implicates the Free Exercise Clause. At issue in Barnette was the constitutionality of a resolution requiring students to salute the flag and recite the Pledge of Allegiance. The Court stated:
It is now a commonplace that censorship or suppression of expression of opinion is tolerated by our Constitution only when the expression presents a clear and present danger of action of a kind the State is empowered to prevent and punish. ... To sustain the compulsory flag salute we are required to say that a Bill of Rights which guards the individual’s right to speak his own mind, left it open to public authorities to compel Mm to utter what is not in his mind. [Id. at 633-634.]
The "clear and present danger” test is an historic and important part of free speech jurisprudence. See Schenck v United States, 249 US 47; 39 S Ct 247; 63 L Ed 470 (1919); Abrams v United States, 250 US 616; 40 S Ct 17; 63 L Ed 1173 (1919); Gitlow v New York, 268 US 652; 45 S Ct 625; 69 L Ed 1138 (1925); Dennis v United States, 341 US 494; 71 S Ct 857; 95 L Ed 1137 (1951). The "clear and present danger” inqmry represents an approach to free speech issues that is inapplicable to our present Free Exercise Clause inquiry,
Id.
MCL 388.551-388.555, 388.557-388.558; MSA 15.1921-15.1925, 15.1927-15.1928.
MCL 388.553; MSA 15.1923.
MCL 388.551; MSA 15.1921.
See MCL 380.1531; MSA 15.41531.
Ante at 296.
MCL 380.1233; MSA 15.41233.
MCL 380.1233(3); MSA 15.41233(3), provides an exception for vocational instructors. Through June 30, 1995, the local school board may renew an annual vocational authorization of a noncertified vocational instructor, provided that the instructor is enrolled and completing credit in an approved vocational teacher preparation program, and that the instructor has a program on file with the employing school district, the educational institution, and the Department of Education.
See MCL 380.1233b; MSA 15.41233(2).
Id.
1989 AACS, R 390.1101 et seq.
"Michigan teaching certificate” means any of the following:
(1) A permanent certificate.
(ii) A life certificate.
(iii) A provisional certificate.
(iv) An occupational education certificate.
(v) A continuing certificate.
(vi) A professional education certificate.
(vii) A temporary or full vocational authorization. [1989 AACS, R 390.1101(f).]
"Vocational authorization” is actually included within the definition of "Michigan teaching certificate.” 1989 AACS, R 390.1101(f)(vii). However, because the Teacher Certification Code provides separate guidelines for its application and issuance, I have chosen to note its existence independently of the teacher certificate. See 1989 AACS, R 390.1162; 1987 AACS, R 390.1165.
1989 AACS, R 390.1141 to 390.1143; R 390.1145 to 390.1146.
(1) A full-year special permit shall be issued when a properly certificated teacher is unavailable for a regular teaching assignment.
(2) An application for a full-year special permit shall contain evidence that the candidate has completed 120 semester hours of satisfactory college credit, as defined in R 390.1141 including 15 semester hours of appropriate professional education credit.
(3) A full-year special permit is valid for teaching in the grades or subjects or grade and subjects specified on the permit until June 30 of the school year for which the permit is issued.
(4) A full-year special permit will be renewed when evidence is presented that a person has completed 6 semester hours of satisfactory additional credit applying on requirements for regular certification and that a properly certified teacher is unavailable for a regular teaching assignment. [1989 AACS, R 390.1142.]
(1) An application for a substitute permit shall contain evidence that the candidate has completed not less than 120 *313semester hours of satisfactory credit in an approved teacher preparation program, which shall include a minimum of 6 semester hours of professional education credit. Persons who are currently enrolled in an approved teacher preparation program will be considered to have met the 6-semester-hour requirement.
(2) A substitute permit is valid for teaching on a substitute basis for a maximum of 150 days during any school year. Teaching on a substitute basis means teaching when the regular certificated teacher is temporarily absent. Such permit is not valid for any regular or extended teaching assignment.
(3) A substitute permit is renewable each year. [1989 AACS, R 390.1143.]
Ala Code 16-28-3.
Ala Code 16-28-5.
See Cal Ed Code 48224.
Kan Stat Ann 72-llll(aX2).