After a recent fatal abuse case involving a homeschooled child, some are calling for stronger regulations.

The recent death of Geanna Bradley, a 10-year-old Wahiawa girl who police say faced “chronic abuse” at the hands of her legal guardians, immediately sparked questions about how her mistreatment could have gone unnoticed for so long. 

Geanna had been homeschooled for more than a year before her death, meaning she was isolated from teachers, counselors and other school employees mandated by law to report signs of abuse. 

Isolation is a known risk factor for abuse, according to the Coalition for Responsible Home Education, and in Hawaii, multiple high-profile child abuse and neglect cases have involved children who were homeschooled.

Some political leaders are now questioning the ease with which adults are able to remove children from school and demanding more oversight around homeschooling procedures. 

Friends of Geanna Bradley gathered at the State Capitol to raise awareness about her case in February. (David Croxford/Civil Beat/2024)

Sen. Kurt Fevella, a Republican from Ewa Beach, has submitted a resolution calling on the Department of Education to conduct wellness visits on all children who are taken out of school to be homeschooled.  

But past proposals to further regulate homeschooling have faced strong opposition. Some argue that most homeschooled children have frequent contact with the outside world through extracurricular activities, and too much oversight can infringe on parents’ rights to make decisions about their children’s education. 

“To take your kids out of school is your prerogative,” said Laura Miller, a member of the Hawaii Coalition for Child Protective Reform. “But they do have to be in some kind of justifiable education, and that is where the malfunction was.”

Who Can Homeschool In Hawaii?

In Hawaii, parents and guardians can homeschool their children, regardless of their educational attainment or qualifications. To begin the homeschooling process, parents must submit a DOE form or write a letter notifying the department that the family intends to withdraw the child from school. 

Nearly 4,000 families submitted a form notifying DOE of their intent to homeschool their children so far this academic year.

Parents of foster children or children in custody of the Department of Human Services, though, are strongly discouraged from homeschooling. While there is no state law that prohibits foster children from being homeschooled, it is considered best practice for children in the child welfare system to be enrolled in a public or private school, said Daisy Hartsfield, social services division administrator for DHS.

“It is a benefit to have children in an educational setting where their well-being can be observed by members of the community,” Hartsfield said in a statement. 

Aerial view of house where Geanna Bradley died of abuse.
Geanna Bradley’s body was found at the house at the bottom right on Karsten Drive in Wahiawa. (Kawika Lopez/Civil Beat/2024)

When a child is in foster care or in custody of DHS, social workers have access to their school records and the department is made aware when a parent of one of these children makes a request to homeschool, according to Hartsfield. 

But when a child is no longer in DHS custody, the department has no say over keeping them in school. 

“CWS does not have the constitutional authority to conduct a check at the home of a parent who is homeschooling or permitted access to their child absent consent or some kind of cause to do so,” Hartsfield said. 

In Geanna’s case, her caretakers, Thomas and Brandy Blas, had obtained legal guardianship over her in October 2018, four years before they decided to withdraw her from Iliahi Elementary School. 

As soon as they became legal guardians, the Blases, who are now both charged with second-degree murder, along with Brandy Blas’s mother, Debra Geron, acquired all the rights of parents, and DHS no longer assigned a social worker to Geanna’s case. 

“Geanna was not a child in foster care when she was released from school to be homeschooled,” Hartsfield said in a statement. “Without any safety concerns reported about her, DHS did not have any authority to conduct any wellness checks or visits.”   

Even so, Nonohe Botelho, an independent consultant and advocate for families of violent crime victims, said officials ignored “red flags” when Geanna was withdrawn, such as the fact that her third grade teacher and school counselor both recommended she stay in school because of the progress she was making. 

In 2021, 6-year-old Isabella Kalua was also withdrawn from school under suspicious circumstances in the months preceding her death. 

Isabella Kalua
Isabella Kalua was removed from school despite her teachers’ concerns. (Courtesy:Honolulu Police Department)

A teacher reported in February 2020 that Isabella was exhibiting concerning behavior, like shutting down when asked about her home environment and once “shaking, trembling (and) crying hysterically” after being asked to remove a long sleeve shirt she was wearing under her school uniform, according to a civil complaint filed in August. 

Her parents, Isaac and Lehua Kalua, who are charged with murdering her, formally adopted her in January 2021 and withdrew her from school in June of that year. Police say she died around two months later, though her body has never been found.

DHS said that once the department and Family Court are no longer overseeing a case, parents “have a constitutional right to make decisions about how their child is raised.”

Since the Kaluas were Isabella’s adoptive parents at the time, they had full parental rights.

Asked if DHS had increased concerns about children in homeschool environments, Hartsfield responded: “DHS has the same concerns as every member of the community that has read about and understood the recent deaths of children who were being homeschooled. DHS is committed to working with State partners at the DOE, the Judiciary, and the Legislature to develop whatever legal strategies are available to prevent future horrific incidents.”

Limited Enforcement For Homeschool Policies

Hawaii has some of the strongest regulations around homeschooling, but enforcement can be spotty, said Samantha Field, government relations director of the Coalition for Responsible Home Education, a Massachusetts-based nonprofit advocating for the safety of homeschooled students. 

Unlike most states, she said, Hawaii requires families to submit annual progress reports such as portfolio reviews, standardized tests or formal assessments completed by a certified teacher. In grades three, five, eight and 10, homeschooled students must complete a standardized test, such as the Hawaii Smarter Balanced Assessments, and submit scores to their local school. 

Citing student privacy, DOE declined to answer questions about Geanna’s case, including whether or not the department had received annual progress reports when she was homeschooled. Isabella was only registered as a homeschooled student for a few months before her death, and her parents would not have been expected to submit an annual report.   

If students fail to make academic improvements, principals can request copies of families’ curriculum or recommend that the child re-enroll in school. 

Administrators can make a report of educational neglect to CWS if parents fail to submit their children’s annual reports or ignore principals’ recommendations to enroll their children in school, said DOE deputy superintendent Heidi Armstrong. But until students take their first standardized test in third grade, principals can’t make judgment calls on students’ education. 

“When parents submit that notification of intent to homeschool, they accept complete responsibility for the education of their child,” Armstrong said. 

But despite Hawaii’s regulations around homeschooling, some children slip through the cracks.

Dept of Human Services.
The Department of Human Services cannot deny parents or guardians the ability to homeschool their children. (Cory Lum/Civil Beat/2019)

Field said parents can easily fabricate children’s test results, and nothing in state law mandates that homeschooled students meet regularly with principals or teachers, who are required to report suspected cases of abuse to CWS, sometimes referred to as CPS. 

“The way that CPS functions is based on the assumption that children will exist at a point in time where somebody from CPS can see them,” Field said. “Once a kid is pulled out of traditional school to be homeschooled, that no longer exists.” 

In a third case involving the severe abuse of a homeschooled child, Shaelynn Lehano-Stone was removed from Hilo Union in November 2015 by her grandmother, Henrietta Stone. At the time, Henrietta Stone’s temporary guardianship over her granddaughter had expired, and DOE should not have allowed her to homeschool Shaelynn, said Jon Jacobs, one of the lawyers in the civil case involving the Lehano-Stone family and the state of Hawaii.  

Seven months later, Shaelynn died of cardiac arrest and starvation. At age 9, she weighed just 45 pounds. Based on records provided by the state, Jacobs said, Henrietta Stone never provided an annual homeschool progress report before her granddaughter’s death on June 28, 2016.   

“It’s just a kid who didn’t really have a chance,” Jacobs said. 

Attempted Reform

Previous attempts to place legal restrictions on homeschooling have been met with serious opposition. 

Senate Bill 2323, which was proposed in 2018, would have required all parents wanting to homeschool their children to undergo a background check with the Department of Education and a child abuse and neglect history inquiry with CWS. The bill references the case of Peter Kema Jr., who was homeschooled by his parents and severely abused before he died in 1997.

Peter Kamakawiwoole, litigation director of the Home School Legal Defense Association who works with Hawaii families, was one of hundreds of homeschool advocates who testified against the bill. 

Kamakawiwoole said the proposed law was overly intrusive for families and put an unnecessary burden on DOE and CWS. It’s unreasonable for CWS to complete background checks and record reviews for thousands of families at a time, he said, when social workers could better spend their time investigating reports of suspected neglect or abuse. 

Hundreds of advocates strongly opposed 2018 legislative efforts to place more regulations on homeschooled families. (David Croxford/Civil Beat/2023)

“Certainly officials can act and families can be investigated, but it needs to be based on a suspicion of wrongdoing,” Kamakawiwoole said.

The Department of Human Services, which oversees CWS, testified in support of the bill, but said it would need a staff increase or additional funding to meet the new requirements. 

The bill never made it out of its committee in the Senate.

Advocates expect another wave of opposition in response to Fevella’s new resolution, which calls for wellness checks for all homeschooled students. 

June Mather, a board member of the Christian Homeschoolers of Hawaii, said her organization is very concerned. While some homeschool parents may be willing to subject their children to the wellness checks, she said, she believes they shouldn’t face different treatment than families attending public school. 

“Targeting homeschoolers is not really going to be a viable solution,” Mather said, adding that children enrolled in public school can also face long stretches of neglect or abuse at home during breaks and summer vacation. 

Sen. Kurt Fevella recently introduced a resolution calling on DOE to conduct wellness checks on all students who have been removed from public school in favor of homeschooling. (David Croxford/Civil Beat/2023)

Botelho also said she considers Fevella’s resolution too sweeping, but she believes a middle ground can be reached. 

Families who pull their children out of school without filing proper paperwork or under suspicious circumstances should be checked on, she said. Also adoptive parents and guardians receiving state money for children in their custody should be monitored if they elect to homeschool, she said. The Blases were receiving $1,961 a month from the state, according to a police affidavit. 

“That’s our taxpayer dollars,” Botelho said. “That should be another reason why they should’ve been monitored. That’s where I draw the line. You’re not including that broad net of all homeschoolers.” 

Fevella said he submitted his resolution after hearing from concerned constituents who want to prevent future deaths of children in the child welfare system. He called public schools “the first line of defense for our kids” and said he plans to introduce a related bill next year. 

“We failed in every aspect of this young child’s life,” Fevella said, referring to Geanna. “We have to do better as lawmakers, as leaders, as concerned parents and citizens.”

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