Over 600 higher education institutions have been identified as alleged diploma mills by governmental authorities based on criteria set forth in U.S. federal law. The characteristics of religious colleges exempt from State oversight varied based on each States' higher education legislation and implementing policy. The U.S. Constitution was the core document from which States established and defended their oversight requirements for religious colleges. The problem was governments could not effectively exercise oversight of religious affiliated "diploma mills" that invoked first amendment protections. The purpose of this multi-case explanatory qualitative research was to study unaccredited religious colleges in order to identify differentiating characteristics between schools government organizations determined were acceptable from schools they determined were unacceptable and alleged to be diploma mills in order to understand how alleged diploma mills defended their operations. Two unaccredited religious colleges government officials considered acceptable were studied for cross-case comparison with four unaccredited religious schools government officials alleged were diploma mills. The four diploma mill cases selected from a population of 19 diploma mill cases were from the States of Louisiana, Texas, Washington, and Wyoming. The research design consisted of document analysis of public records and interviews of government officials to validate the document analysis findings. The key findings were: 1) variations in States' requirements that define religious schools made it difficult for government officials to assess religious schools across the States; 2) a religious school alleged to be a diploma mill may avoid higher education oversight by demonstrating the government impermissibly intruded upon its religious freedom protected by the United States Constitution; and 3) the definition of diploma mill victims has evolved and now includes students who can attain restorative justice by seeking reparation from diploma mill operators. The research found the number of variables States used to define religious degree issuing institutions made it difficult for government officials to identify and prosecute alleged diploma mills in order to suppress this type of education fraud. Future research is recommended to understand diploma mill recidivism and establish a uniform law for higher education. [The dissertation citations contained here are published with the permission of ProQuest LLC. Further reproduction is prohibited without permission. Copies of dissertations may be obtained by Telephone (800) 1-800-521-0600. Web page: http://bibliotheek.ehb.be:2222/en-US/products/dissertations/individuals.shtml.]