A major concern about public funding of school choice is government control of private schools. “Who pays the piper calls the tune,” the argument goes. For example, in higher education, college students receiving assistance under the federal Basic Educational Opportunity Grants program (BEOG) subject the college to the provisions of Title IX, which bars sex discrimination by institutions receiving “federal financial assistance.” The U.S. Supreme Court so ruled in Grove City College v. Bell in 1984. While Grove City is accepted by many as proof that government funding leads to government control, a different perspective was provided by the late...