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Cleveland Board of Education v. LaFleur

Mandatory Maternity Leave

The second half of the twentieth century witnessed a rapid expansion of the role and status of women outside the home. As women increasingly occupied important positions in business and the professions, they were often faced with archaic rules governing gender-related health issues. Among such rules were those that enabled employers to dismiss or force into unpaid leave of absence those workers who became pregnant. Just such a rule was maintained by the Cleveland, Ohio school board to govern maternity leave. Under the policy, pregnant teachers were required to go on unpaid leave beginning five months before the expected birth date of their child. Furthermore, teachers were not allowed to return to work under the policy until the semester following their child's attaining the age of three months, subject to medical approval.

During the 1970-71 school year Cleveland, Ohio junior high school teachers Jo Carol LaFleur and Mary Elizabeth Nelson informed the school board that they were pregnant, and were forced to go on unpaid leave in March of 1971 in accordance with the policy. Neither LaFleur nor Wilson wished to take their leave at that time, preferring instead to wait until the end of the school year in June. As such, they each brought suit against the school board in the U.S. District Court for the Northern District of Ohio, challenging the constitutionality of the policy. The district court rejected LaFleur and Nelson's contentions, holding that the policy was constitutional. The respondents then appealed the case to the U.S. Court of Appeals for the Sixth Circuit, which reversed the decision of the district court on the grounds that the policy violated the Equal Protection Clause of the Fourteenth Amendment. The school board then appealed the case to the U.S. Supreme Court, which heard arguments on the matter on 15 October 1973.

Additional topics

Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1973 to 1980Cleveland Board of Education v. LaFleur - Significance, Mandatory Maternity Leave, A Violation Of Due Process?, Impact, Maternity Leave, Further Readings