In Pater v. Pater, 63 Ohio St.3d 393, 395, 588 N.E.2d 794, at issue was the effect that the religious practices of the mother, a Jehovah's Witness, would have on the child if the court granted custody to the mother instead of the father, a Roman Catholic. In reversing the award of custody to the father, the court determined that "custody may not be denied to a parent solely because she will not encourage her child to salute the flag, celebrate holidays, or participate in extracurricular activities," and the court also determined that the trial court's orders were improperly based on the mother's religious beliefs. Id., at 395-96. The court noted that "parents have a fundamental right to educate their children, including the right to communicate their moral and religious values." Id.