Cleveland Board of Education v. LaFleur
Cleveland Board of Education v. LaFleur | |
---|---|
Case history | |
Prior |
|
Holding | |
Overly restrictive maternity leave regulations in public schools violate the Due Process Clause of the Fifth and Fourteenth Amendments. | |
Court membership | |
| |
Case opinions | |
Majority | Stewart, joined by Brennan, White, Marshall, Blackmun |
Concurrence | Douglas |
Concurrence | Powell |
Dissent | Rehnquist, joined by Burger |
Laws applied | |
U.S. Const. amends. V, XIV |
Cleveland Board of Education v. LaFleur, 414 U.S. 632 (1974), found that overly restrictive
Facts
The plaintiffs claimed that an employer's requirement to take maternity leave from public schools violated the Due Process Clause of the Fourteenth Amendment.
Judgment
On January 21, 1974, the Court delivered its ruling. The majority opinion was delivered by Justice Stewart.
The Supreme Court ruled that the mandatory maternity leave rules were unconstitutional under the Due Process Clauses in the Fifth and Fourteenth 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 Court's opinion, 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]
Significance
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 LaFleur can also be seen as a building block for current family leave laws, e.g. Family and Medical Leave Act of 1993, which help to ensure that all people can keep their professions without giving up the ability, and the means, to have a family.
After the war, many married women remained employed as teachers; however, traditional prejudices against them endured. The attitude changed focus into
See also
- US labor law
- List of United States Supreme Court cases, volume 414
- Cleveland Board of Education v. Loudermill (1985) - Another case involving the school district
References
- ^ a b c d Cleveland Board of Education v. LaFleur, 414 U.S. 632 (1974). This article incorporates public domain material from this U.S government document.
- ^ a b c d "Pregnant Teachers in the Classroom: paper summary by Georgetown Law". Archived from the original on September 10, 2006. Retrieved February 11, 2007.
External links
- Text of Cleveland Board of Education v. LaFleur, 414 U.S. 632 (1974) is available from: Cornell CourtListener Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)