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This policy analysis examines teacher quality in light of the Renee v. Duncan decision and the Congressional response to the ruling through the Continuing Resolution bill, H.R. 3082 §163. Citing portions of the No Child Left Behind Act (NCLB) of 2001 and the Secretary of Education’s subsequent regulations intended to make clear guidelines for certifying highly qualified teachers, the court disentangled the federal statute and federal regulation, illuminating their contradictory language. Meanwhile, Congress intervened by passing a temporary addendum to NCLB, bestowing highly qualified status upon alternative pathway teachers who have not attained full state certification. This paper explores policy configurations of teacher quality with particular emphasis on examining the teaching certificate as a valid reliable indicator of teacher quality.