After "Zelman v. Simmons-Harris" (2002), civil conflict over use of vouchers and taxes to purchase private education, especially in religious schools, largely remained an issue for state courts' jurisprudence. However, in 2010, it returned to the U.S. Supreme Court when Arizona taxpayers challenged the constitutionality of the state's education tax credit program permitting private donations to student tuition organizations that in turn provide scholarships for student attendance at private schools. This article describes selected U.S. education tax credit programs used to purchase private education, their legal sustainability, and the ongoing public policy debate.