The relationships of learning and teaching that occur out-of-school such as health, nutrition, childcare practices, cultural practices in the community and home, expectations, and other supports for academic development to the effectiveness of the teaching and learning that occur in school. Bourdieu, a French social theorist, has referred to these resources as education relevant forms of capital that can be invested in education. Despite this line of thought, throughout the 20th century and now in the 21st century with a radically different approach to national governance, the focus of intervention addressed at the reduction of the academic achievement gap is focused on school reform. The relationship of education to the civil rights struggle focuses on education of high quality as a civil right. This means that learners exercise the liberty of becoming intellectively competent, while society must continue to protect and provide a safety net under the existence of all children.