Spoilers for episodes 1–3 of Carrie (Prime Video, 2026).

This month I posted a draft law review article, Not the Mere Creature of Anyone: Parental Control, Public Money, and the Case for Children’s Educational Rights. Its argument is that for a century the Supreme Court has asked one question about children’s schooling, how much control parents get, and has almost never asked the other: what is the child owed? (I walked through the argument in an earlier post.)
Then I started watching Mike Flanagan’s Carrie on Prime Video, and I couldn’t get the article out of my head. What struck me most was how Carrie’s teachers, and especially her school counselor, reached out to her and cared for her, all while working inside the very constraints the article describes.
I did not expect a Stephen King adaptation to be the clearest illustration of that argument I’ve seen. It is.
Flanagan’s Carrie White is not just a bullied teenager with a fanatical mother. She is a child who was, for roughly fifteen years, legally invisible. And the only reason she ever sees the inside of a school is a plot device that our law does not reliably supply: a death in the family that triggers a welfare check.
Fifteen years in the house: exit with no one watching
The series opens after Carrie’s father Ralph dies in a construction accident. Social workers conducting a welfare check find Margaret and her teenage daughter, a girl who has essentially never left the family home. As a condition of Margaret keeping custody, Carrie must attend the local high school. Margaret, for her part, promises Carrie it will only be for a semester, two at most.
Up to that point, Carrie had been “homeschooled,” in the loosest possible sense. She was allowed to read little beyond the Bible. What she knows of the wider world of books she owes almost entirely to a neighbor, Stella, who as a girl began slipping books into the birdhouse Carrie was permitted to tend, the one point of contact she had with the outside.
Sit with that for a moment, because it is a precise picture of the regime described in Part I.D of the article. The Supreme Court has never decided a home schooling case. Home schooling’s legality rests on state statutes read against Pierce v. Society of Sisters, and those statutes range from notice and portfolio review to almost nothing at all. Carrie’s entire educational recourse, for a decade and a half, was the private generosity of a kid next door with a library card. No registry knew she existed. No assessment measured what she had learned. No teacher, nurse, or counselor (no mandated reporter) ever laid eyes on her.
Pierce itself did not contemplate this. The Court was explicit that nothing in its holding questioned “the power of the State reasonably to regulate all schools, to inspect, supervise and examine them, their teachers and pupils.” Pierce was a bargain: parents could leave the public schools, and the State kept the power to make sure the child was educated anyway. In Carrie’s case, the first half of the bargain was honored for fifteen years. The second half never showed up.
The welfare check: the state as guarantor, by accident
The show’s premise, that the state conditions Margaret’s custody on Carrie’s school attendance, is the closest thing in the story to the framework I call Children’s Recourse. It is the state acting as guarantor of a real education for a child whose parent has failed her.
There is doctrinal room for it. Prince v. Massachusetts remains the clearest statement that parental and religious authority yields to the state’s interest in the child’s welfare: parents “may be free to become martyrs themselves,” but they are not free “to make martyrs of their children.” Even Mirabelli v. Bonta, which this spring expanded parents’ rights to be informed about what happens at school, preserved a carve-out: the State may still “shield children from unfit parents by enforcing child-abuse laws and removing children from parental custody in appropriate cases.” A prayer closet used as a punishment cell is squarely what child-abuse laws are for.
But notice how the state got there. Not through any system designed to find a child like Carrie. It got there because her father died and someone came to the door. Under DeShaney, the state generally owes a child no duty to protect her from harm inflicted by a private actor, including a parent. Absent the accident, Carrie stays in the house, and nothing in federal constitutional law obliges anyone to come looking.
Inside the school: what Mahmoud and Mirabelli would hand Margaret

Once Carrie is in school, the show becomes a story about a child discovering what she has been denied, and a mother trying to claw it back.
In episode two, the guidance counselor, Peter Morton, is among the first adults to treat Carrie kindly. He answers her questions and walks her into the school library, a place she has never been. The titles she pulls off the shelf, as Forbes noted, are drawn from authors whose books are among the most frequently challenged in American schools. Carrie wants to read. She wants to understand her own body, which no one has explained to her, and she gets materials and answers from the adults at school that her mother would never have provided. Margaret, true to form, wants her out of all of it.
Twenty years ago, Margaret’s objections would have gone nowhere. The baseline the lower courts drew from Barnette (Mozert in 1987, Parker v. Hurley in 2008) was that being exposed to material in school is not a constitutional injury. Parents who objected could leave. They could not veto.
That baseline is gone. Under Mahmoud v. Taylor, a parent’s free exercise rights are violated by school policies that “substantially interfere with the religious development” of the child, and a burden of the same character as Yoder triggers strict scrutiny even under a neutral, generally applicable policy. Margaret White is close to a law school hypothetical for that test: sincere, all-encompassing religious objection to the library’s novels, to sex education, to the very idea that Carrie’s body is something she is entitled to understand. Mirabelli adds a second weapon. The Court found parents likely to succeed in claiming a right to participate in “decisions regarding their children’s mental health,” which is to say, in what passes between Carrie and Mr. Morton.

What neither opinion contains is any account of Carrie’s side. As Part II.D of the article puts it, a child’s interest in learning about the world as it is, in confidential access to a school counselor, and in developing views of her own appear in these opinions only as interests the parental right overrides. They are never treated as rights the child holds.
Justice Douglas saw this coming in Yoder. The children’s own views had not been canvassed, he wrote, and “the children should be entitled to be heard.” Carrie is sixteen or seventeen. She has views. She is literally reading her way out of the house. Under current doctrine, no court would ask her.
Compare England. Its statutory guidance on sex education lets a pupil, from three terms before age sixteen, opt into sex education even over a parent’s withdrawal. Carrie, in England, would have her own say. In the U.S., after Mahmoud, the opt-out runs one way.
Follow the money: the Carrie the state would never have found

Now change one fact. Suppose Margaret White lived in Arizona, and suppose that instead of keeping Carrie home on her own dime, she had signed up for an Empowerment Scholarship Account. I took up exactly this scenario in Experimenting With Our Children, which asks who answers to the eighteen-year-old the voucher failed.
Under Arizona’s statute, a parent’s signature on the account agreement “constitutes school attendance” for purposes of compulsory attendance law. The account requires spending on reading, math, and the other basic subjects, but imposes no testing, no curricular approval, and measures no learning. Florida’s home-education account requires a test to be taken and reported; funding turns on submitting it, not on the score.
In that world, the welfare check does not end with a custody condition. Margaret has a signed account agreement that counts as attendance and a stream of public money to prove it. Carrie’s “education” is a ledger of receipts. And after Carson v. Makin, a state that funds private options cannot exclude a family because the instruction it funds is religious. (The series, like King’s novel, is set in Chamberlain, Maine. Carson is a Maine case.) If the Court rules in St. Mary Catholic Parish v. Roy, argued November 3, that neutral conditions cannot bind religious providers, even the conditions a state might want to attach will be in doubt. Preston Green and I sketched where this sequence leads back in 2020, in The Post-Espinoza End Game.
The point is not that religious families shouldn’t get public support. The Netherlands funds private religious schools on the same footing as public ones. The point is that every peer democracy that does so exchanges that support for public accountability, and that money flowing in a child’s name ought to carry some obligation running to the child. Under the doctrine as it stands, it carries none.
What Carrie is owed: the state constitutional right that follows the child
The guidance office is where Carrie’s world opens up. Mr. Morton’s trip to the library is the first time an adult at any institution asks her what she wants to read. It’s a small scene, but it points straight at the question school finance people spend their careers on: not what a parent prefers, but what the state has actually promised each child.
Kentucky’s high court in Rose defined an adequate education in terms of capacities every child must have the opportunity to develop, including enough knowledge of economic, social, and political systems to make informed choices. New York’s Court of Appeals has said a sound basic education must prepare students to compete for jobs that support them and to function as civic participants. Several state high courts, including Kentucky, Wyoming, New Hampshire, and Washington, have called the right fundamental, and have described it as one held by each child.
A right like that does not stay behind when a child leaves the public system. It follows her. On that reading, the relevant question about Carrie is not whether her absence harmed the local public school’s budget. It is whether the state secured for her, at any point in fifteen years, the capacities its constitution guarantees. The honest answer is no, and the only thing that changed it was a funeral.
Children’s Recourse, applied to Carrie White
Part VII of the article lists measures a state can adopt now, on the authority Pierce itself reserved, without overruling anything. Here is how each would have changed Carrie’s story.

| Children’s Recourse measure | What it would have meant for Carrie |
|---|---|
| Register every school-age child, in any setting | The state knows Carrie exists before age 16, not because of a death |
| Assess learning, not attendance or receipts; remediate, then require a change of setting after repeated failure | A Bible-only curriculum shows up in an assessment years earlier |
| Keep every child in periodic contact with a mandated reporter | Someone other than Stella sees Carrie, and the prayer closet, long before high school |
| Attach neutral accountability conditions to every public dollar | If Margaret’s home schooling were publicly funded, the money would buy measurable learning, not a signature |
| Give older students a statutory voice in decisions about their own schooling | Carrie’s wish to read, and to learn about her own body, counts for something against Margaret’s opt-outs |
| Repeal provisions that deem a funding contract to be school attendance | Margaret cannot convert an account agreement into a shield against the welfare check |
None of these measures requires Margaret to renounce her faith or Carrie to profess anything. They are deliberately content-neutral. That matters, and I want to be careful here, because Margaret White is a horror-movie caricature of religious motherhood, and it would be easy, and wrong, to read this post as an argument that religious parents are the problem. Pierce protected Catholic families from a Klan-backed law; Meyer and Farrington protected German and Japanese American families. Any framework that expands state authority over schooling has to be built so it cannot be turned against minority families again. That is why Children’s Recourse locates the right in the child, not in the state’s preferences about culture or creed. The European Court of Human Rights draws the line at indoctrination, not exposure, and it has held that a child’s interest in a well-rounded education can outweigh a parent’s religious objection to particular lessons. That’s a workable model.
The only recourse in the story
Carrie is a horror story, and the genre gives its heroine one form of recourse: telekinesis. Every adult institution in her life, the family, the church, the school, the state, fails her or arrives too late, and she answers with the only power she has.
Real children don’t have that option. What they have, or ought to have, is law. Right now, the law the Court has built treats Carrie as the object of her mother’s liberty, funds her mother’s exit if her state chooses to fund exit at all, lets her mother veto what the school teaches her once she’s inside, and asks Carrie nothing.
Pierce told us that “the child is not the mere creature of the State.” True. Nor is she the mere creature of her mother, or of a neighbor’s birdhouse, or of a lucky welfare check. If we are going to let a parent hold a child’s education in her hands, and especially if we are going to pay for it, someone has to be answerable to the child.
Read the full draft: Baker, B.D. (2026, October). Not the mere creature of anyone: Parental control, public money, and the case for children’s educational rights. School Finance 101 Working Paper.
Related posts on School Finance 101
- Not the Mere Creature of Anyone: A Century of Parental Control Over Schooling, and the Case for Children’s Recourse (October 2026)
- Experimenting With Our Children: Who Answers to the 18-Year-Old the Voucher Failed? (October 2026)
- An Economically Conservative Approach to Deciding Whether to Adopt or Expand Vouchers (October 2026)
- Preserving an Educated Future for America (Short Term Plan) (May 2025)
- Charter Schooling in the Post-Espinoza & Fulton Era (July 2021)
- The Post-Espinoza End Game (with Preston Green) (July 2020)
- On Private Schools and Discrimination (Preston Green) (February 2020)
- The Efficiency Smokescreen: The 3 Kansas Judges Who Saw Right Through It (January 2013)














































