Cleveland Board of Education v. LaFleur
A Violation Of Due Process?
The Court held the policy to be unconstitutional under the Due Process Clause of the Fourteenth Amendment by a 7-2 margin. Writing for the majority, Justice Stewart noted that the Court had long since established that "freedom of personal choice in matters of marriage and family life is one of the liberties protected by the Due Process Clause of the Fourteenth Amendment" in numerous cases, including Prince v. Massachusetts (1944), Griswold v. Connecticut (1965), and Roe v. Wade (1973). As such, any policy of an employer regarding employees who decide to become pregnant must not "needlessly, arbitrarily, or capriciously impinge upon this vital area of a [person's] constitutional liberty." In fact, the school board had argued along these lines, advancing the position that the maternity leave policy was essential to maintaining "continuity of classroom instruction" for its students. Sending teachers on their enforced maternity leave so long before their due date, the school board argued, was an administrative imperative given the difficulty of securing a long-term substitute teacher and the necessity of insuring that pregnant teachers did not become debilitated on the job.
In rejecting the school board's arguments, the Court observed that the policy could, in fact, impede the continuity of classroom instruction, depending upon the point in the school year at which the teacher was forced to go on leave. Furthermore, the physical ability to remain on the job while pregnant varied greatly among individual women, rendering any policy mandating that all pregnant women cease work at the same point in their pregnancies arbitrary. The Court maintained that the only way to determine a pregnant woman's fitness to continue in her job was on a strictly medical basis.
The Court also ruled that the policy's provisions for the return to work of women that were on maternity leave were unconstitutional under the Due Process Clause. Once again, given the differing physical capacities of individuals, any policy dictating the time of return for all workers was, by definition, arbitrary. The school board could continue to require teachers wishing to return to work following maternity leave to first secure verification of their fitness from a physician.
- Cleveland Board of Education v. LaFleur - Impact
- Cleveland Board of Education v. LaFleur - Mandatory Maternity Leave
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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