Cleveland Bd. of Educ. v. LaFleur - 414 U.S. 632 (1974)
U.S. Supreme Court
Cleveland Bd. of Educ. v. LaFleur, 414 U.S. 632 (1974)
Cleveland Board of Education v. LaFleur
Argued October 15, 1973
Decided January 21, 1974
414 U.S. 632
Pregnant public school teachers brought these actions under 42 U.S.C. § 1983 challenging the constitutionality of mandatory maternity leave rules of the Cleveland, Ohio (No. 72-777), and Chesterfield County, Virginia (No. 72-1129), School Boards. The Cleveland rule requires a pregnant school teacher to take unpaid maternity leave five months before the expected childbirth, with leave application to be made at least two weeks before her departure. Eligibility to return to work is not accorded until the next regular semester after her child is three months old. The Chesterfield County rule requires the teacher to leave work at least four months, and to give notice at least six months, before the anticipated childbirth. Reemployment is guaranteed no later than the first day of the school year after the date she is declared reeligible. Both schemes require a physician's certificate of physical fitness prior to the teacher's return. Each Court of Appeals reversed the court below, one holding the Chesterfield County maternity leave rule constitutional, the other holding the Cleveland rule unconstitutional.
1. The mandatory termination provisions of both maternity rules violate the Due Process Clause of the Fourteenth Amendment. Pp. 414 U. S. 639-648.
(a) The arbitrary cutoff dates (which obviously come at different times of the school year for different teachers) have no valid relationship to the State's interest in preserving continuity of instruction, as long as the teacher is required to give substantial advance notice that she is pregnant. Pp. 414 U. S. 639-643.
(b) The challenged provisions are violative of due process, since they create a conclusive presumption that every teacher who is four or five months pregnant is physically incapable of
continuing her duties, whereas any such teacher's ability to continue past a fixed pregnancy period is an individual matter, and the school boards' administrative convenience alone cannot suffice to validate the arbitrary rules. Pp. 414 U. S. 643-648.
2. The Cleveland three-month return provision also violates due process, being both arbitrary and irrational. It creates an irrebuttable presumption that the mother (whose good health must be medically certified) is not fit to resume work, and it is not germane to maintaining continuity of instruction, as the precise point a child will reach the relevant age will occur at a different time throughout the school year for each teacher. Pp. 414 U. S. 648-650.
3. The Chesterfield County return rule, which is free of any unnecessary presumption, comports with due process requirements. P. 414 U. S. 650.
No. 72-777, 465 F.2d 1184, affirmed; No. 72-1129, 474 F.2d 395, reversed and remanded.
STEWART, J., delivered the opinion of the Court, in which BRENNAN, WHITE, MARSHALL, and BLACKMUN, JJ., joined. DOUGLAS, J., concurred in the result. POWELL, J., filed an opinion concurring in the result, post, p. 414 U. S. 651. REHNQUIST, J., filed a dissenting opinion, in which BURGER, C.J., joined, post, p. 414 U. S. 657.