Cleveland Board of of Education v. LaFleur
414 U.S. 632 (1974)

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U.S. Supreme Court

Cleveland Bd. of Educ. v. LaFleur, 414 U.S. 632 (1974)

Cleveland Board of Education v. LaFleur

No. 72-777

Argued October 15, 1973

Decided January 21, 1974*

414 U.S. 632

Syllabus

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.

Held:

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

Page 414 U. S. 633

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.

Page 414 U. S. 634

Primary Holding
Employers may not impose rules that create conclusory presumptions about the ability of pregnant women to perform their job duties for a certain period before and after childbirth, since these have no rational connection to the legitimate state interest of preserving continuity of instruction in schools, as long as notice of leave is required.
Facts
The city of Cleveland, Ohio had a rule for its school board that compelled pregnant teachers to take unpaid maternity leave five months before the anticipated birth of a child. The rule also did not allow the teachers to return until the beginning of the next school term after the child turned three months old. Chesterfield County in Virginia had a similar rule that required at least four months of unpaid maternity leave with six months of notice before childbirth. Pregnant schoolteachers challenged each rule on the basis that they violated due process.

Procedural History

U.S. District Court for the Northern District of Ohio - 326 F. Supp. 1208

The district court tried the two teachers' cases together and found for the defendant Board of Education.

U.S. Court of Appeals for the Sixth Circuit - 465 F. 2d 1184

A divided panel of the appeals court reversed the lower court, finding the mandatory maternity rule violated the Equal Protection Clause of the Fourteenth Amendment.

U.S. District Court for the Eastern District of Virginia - 326 F. Supp. 1159

The district court found for the plaintiff teacher, holding that the school board regulation violates the Equal Protection Clause of the Fourteenth Amendment.

U.S. Court of Appeals for the Fourth Circuit - 474 F.2d 395

A panel of the Fourth Circuit affirmed the lower court, but the Fourth Circuit sitting en banc upheld the constitutionality of the regulation, thereby reversing the trial court.

Attorneys
  • Charles F. Clarke
  • Philip J. Hirschkop
  • John B. Mann
  • Jane M. Picker
  • Rita Page Reuss
  • Sidney Picker, Jr.
  • Samuel W. Hixon III
  • Frederick T. Gray

Issues & Holdings

Issue: Whether the Cleveland three-month return provision is unconstitutional.
Holding: Yes. The Cleveland three-month provision violates due process because it is arbitrary and irrational. It creates an irrebuttable presumption that the mother is not fit to resume work.

Issue: Whether the Chesterfield County return rule is unconstitutional.
Holding: No. The Chesterfield County return rule, unlike that of the Cleveland rule, is free of any unnecessary presumptions and comports with due process requirements.

Opinions

Majority

  • Potter Stewart
  • William Joseph Brennan, Jr.
  • Byron Raymond White
  • Thurgood Marshall
  • Harry Andrew Blackmun

Concurrence

  • William Orville Douglas (Author)

Concurrence

  • Lewis Franklin Powell, Jr. (Author)

Dissent

  • William Hubbs Rehnquist (Author)
  • Warren Earl Burger

Case Commentary

It is worth noting that, while the Court ruled in favor of the women, it grounded its reasoning under the Due Process Clause rather than the Equal Protection Clause of the Fourteenth Amendment. Most cases involving disparate treatment of genders unfold under equal protection, and the lower court had used that basis in one of the cases, but the Supreme Court was not ready to take that step.

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