Cleveland Board of Education v. LaFleur
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| Cleveland Board of Education v. LaFleur | ||||||||||||
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| Argued October 15, 1973 Decided January 21, 1974 |
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| 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 |
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| Case opinions | ||||||||||||
| Majority by: Stewart Joined by: Brennan, White, Marshall, Blackmun Concurrence by: Douglas Concurrence by: Powell Dissent by: 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 late coming triumph for the women's rights movement.
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[edit] 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 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 stayed employed as teachers, however, prejudice remained. The prejudice simply changed focus to discriminate 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, and virtually all were unpaid. Essentially, women who were visibly pregnant were not allowed to work. The stated rational 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.
[edit] 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, and 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.
