This Comment summarizes the existing comprehensive analysis of federal and state constitutional challenges to voucher programs. It examines how the groundbreaking Cleveland and Milwaukee plans addressed these critical issues, and makes suggestions for legislators wishing to implement similar plans in their states. The suggestions are intended to: 1) facilitate the passage of such measures; 2) mitigate the most divisive arguments of voucher opponents; 3) allay the fears of the legislators and their constituents; and 4) fortify such plans against probable legal challenges.

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