Cleveland Board of Education v. LaFleur

Cleveland Board of Education v. LaFleur
Supreme Court of the United States
Argued October 15, 1973 Decided January 21, 1974
Full case name	Cleveland Board of Education v. Jo Carol LaFleur
Citations	414 U.S. 632 (more) 94 S. Ct. 791; 39 L. Ed. 2d 52; 1974 U.S. LEXIS 44; 6 Fair Empl. Prac. Cas. (BNA) 1253; 7 Empl. Prac. Dec. (CCH) P9072; 67 Ohio Op. 2d 126
Prior history	Cert. to the U.S. Court of Appeals for the Sixth Circuit
Holding
Overly restrictive maternity leave regulations in public schools violate the Due Process Clause of the Fifth and Fourteenth Amendments.
Court membership
Chief Justice Warren E. Burger Associate Justices William O. Douglas · William J. Brennan, Jr. Potter Stewart · Byron White Thurgood Marshall · Harry Blackmun Lewis F. Powell, Jr. · William Rehnquist
Case opinions
Majority	Stewart, joined by Brennan, White, Marshall, Blackmun
Concurrence	Douglas
Concurrence	Powell
Dissent	Rehnquist, joined by Burger

Cleveland Board of Education v. LaFleur, 414 U.S. 632 (1974)^[1] found that overly restrictive maternity leave regulations in public schools violate the Due Process Clause of the Fifth Amendment and the Fourteenth Amendment. This decision, which unequivocally struck down mandatory maternity leave rules, was a triumph for the women's movement.

Background

Teaching was one of the first careers outside of the home which was open to American women. As a result, in the late 19th century and the 20th century, women dominated the field of teaching. In 1919, 86% of teachers were women.^[2] However, a prejudice was still widely held in American society which enforced the belief that a women’s primary role should be that of housewife. This bias was also shared by the male administrators and politicians, who largely dominated schools of these centuries, and thus married women were discouraged from, and overlooked for, teaching positions. This was justified by the belief that men and single women needed the jobs more. Only after the World War II labor shortages were married women widely hired as teachers.^[2]

After the war, many married women remained employed as teachers; however, prejudice against them endured. The prejudice simply changed focus into discrimination against pregnant women. In 1948 an National Education Association survey showed 43% of schools as having no maternity leave, and the rest having compulsory maternity leave^[2]. The compulsory maternity leave rules were very discriminatory as they implied that women were incapable of making their own decisions about work, health care, and their professional competency. Most of these compulsory maternity leave rules required teachers to take leave 4–6 months before childbirth until well after the child was born. Virtually all maternity leaves were unpaid. Essentially, women who were visibly pregnant were not allowed to work. The stated rationale of these compulsory maternity leave laws were: that pregnant women could not meet the physical or mental demands of the job, that pregnancy interrupted the continuity of instruction for students, and that pregnant women might get hurt on the job.^[1][2] In this case the court found that this reasoning was faulty, as women do not lose all sense and ability simply because they are visibly pregnant.

The Decision

On January 21, 1974, the court delivered its ruling. The majority opinion of the court was delivered by Justice Potter Stewart.

The Supreme Court ruled that the mandatory maternity leave rules were unconstitutional under the Due Process Clauses in the 5th and 14th amendments. Essentially, the rules were found to be too arbitrary (fixed dates chosen for no apparent reason) and irrebuttable (having no relation to individual medical conditions and with no way to make exceptions for good reason).^[1] In the Opinion of the Court, Justice Stewart went on to explain:

"This Court has long recognized that freedom of personal choice in matters of marriage and family life is one of the liberties protected by the Due Process Clause ... By acting to penalize the pregnant teacher for deciding to bear a child, overly restrictive maternity leave regulations can constitute a heavy burden on the exercise of these protected freedoms. .. (P)ublic school maternity leave rules directly affect "one of the basic civil rights of man," ... the Due Process Clause of the Fourteenth Amendment requires that such rules must not needlessly, arbitrarily, or capriciously impinge upon this vital area of a teacher's constitutional liberty."^[1]

This decision was a major step in protecting the rights of teachers, especially female teachers, from unfair prejudicial rules which would keep them from the profession of teaching. This decision also plays a critical role in the professionalization of teaching by protecting all teachers from arbitrary, political regulations which serve no pedagogical function. The case of LeFleur can also be seen as a building block for current family leave laws, which help to ensure that all people can keep their professions without giving up the ability, and the means, to have a family.

See also

• List of United States Supreme Court cases, volume 414

References

1. ^ ^{a b c d} Full text of the decision courtesy of Findlaw.com
2. ^ ^{a b c d} Pregnant Teachers in the Classroom: paper summary by Georgetown Law