You know, there's not a lot of hard data on it. But consider for a moment what the high-profile cases are, and the response to them. There's rarely any serious repercussions, and the school usually backs the teacher. A few years back, a social studies teacher in NJ was telling his students that evolution was false and non Christian students were going to H, and the school first tried to claim the student was lying, then tried to discipline the student because he had taped it. It's unknown if the teacher received any punishment, but he continued to work at the school for years. This year, a school in Alabama had been contacted by the FFRF because they're holding prayers over the school intercom in the morning. The school is refusing to abandon the practice. And it's gone on for years. Since much less could constitute a violation, I'm sure there's a lot occurring that simply isn't reported, especially since a lot of parents may not want to face repercussions from the community, a lot of parents and teachers won't be sure of what constitutes a violation and what doesn't, and some of the time the parents may be happy with the illegal proselytizing. If 75% of parents' response to harassment were happiness that the teacher was taking an interest in their child, how many headlines did you think we'd see, and do you think harassment would decrease or increase?