Tuesday, March 5, 2013

Cleveland Board of Education v. Lafleur case brief

Cleveland Board of Education v. Lafleur case brief summary
414 U.S. 632 (1974)

SYNOPSIS: Petitioner teachers filed claims against respondent school boards under 42 U.S.C.S. § 1983, challenging the constitutionality of the maternity leave rules.
-The United States Court of Appeals for the Fourth Circuit upheld the constitutionality of the challenged regulations, but the United States Court of Appeals for the Sixth Circuit ruled similar regulations were unconstitutional.
-The Court granted certiorari.

-The school boards' maternity leave regulations required arbitrary dates for when a pregnant teacher had to cease teaching due to her pregnancy.

-The Court held that the freedom of personal choice in matters of marriage and family life was one of the liberties protected by the Due Process Clause of the Fourteenth Amendment.

-The arbitrary cutoff dates embodied in the mandatory leave rules had no rational relationship to the valid state interest of preserving continuity of instruction, and allowing the individual teacher the choice to set firm dates later in pregnancy would serve the boards' objectives, while not violating the teachers' exercise of constitutionally protected freedom.
-The Court held that while it might be easier for the school boards to conclusively presume that all pregnant women were unfit to teach past a certain date, administrative convenience alone was insufficient to make valid what otherwise was unconstitutional.
-The Court also held that any school board regulations which arbitrarily limited the teachers' right to return to teaching suffered from the same constitutional deficiencies that plagued the presumption in the termination rules.

OUTCOME: The Court affirmed the judgment which had ruled the regulations unconstitutional, and reversed the judgment which held the regulations constitutional.

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