Charter schools offer the promise of choice in education, but since these schools are funded by taxpayer money, then these schools can never be independent. In North Carolina, the Charter Day School lost a lawsuit (Peltier v. Charter Day School) about their dress code, because the Fourth Circuit Court of Appeals ruled that the school is a “state actor” and requiring girls to wear skirts violates both the Equal Protection Clause of the U.S. Constitution and Title IX.