Cleveland Board of Education v. LaFleur

Brief Fact Summary.

Teachers brought suit under two state laws placing fixed cutoff dates for mandatory maternity leave and establishing set requirements prior to return.

Synopsis of Rule of Law.

The Due Process Clause of the Fourteenth Amendment requires such rules must not needlessly, arbitrarily, or capriciously impinge upon the vital area of a teacher’s constitutional liberty.

Facts.

A Cleveland Board of Education rule required pregnant school teachers to take maternity leave without pay five months before the expected birth. The teacher is not promised re-employment after birth, but is given priority in reassignment to a qualified position. Failure to comply with the rule is ground for dismissal. Jo Carol LaFleur and Ann Elizabeth Nelson were forced against their wishes to take the mandatory maternity leave.
A Chesterfield County, Virginia School Board maternity leave regulation required pregnant teachers to leave work four months prior to expected birth. Notice in writing was required at least six months prior to birth. A teacher on maternity leave was re-eligible for employment once she submitted written notice from a physician that she was physically fit and could give assurance that the care of her child would cause only minimal interference with her job. The teacher is guaranteed re-employment no later than the first day of the school year following the date she is declared re-eligible. Susan Cohen requested that she be permitted to continue teaching beyond the six month limitation, but was denied.

Issue.

Do the interests advanced in support of the School Boards Rules justify the particular procedures adopted?

Do the particular means chosen to achieve the School Boards’ objectives unduly infringe upon the teachers’ constitutional liberty?

Held.

The School Boards’ rules requiring maternity leave at a specific date for all pregnant individuals is overly broad and violates the Fourteenth Amendment to the United States Constitution. The Cleveland return rule is arbitrary and irrational, and therefore serves no legitimate state interest. The Chesterfield return rule serves a legitimate state purpose and is constitutional.
The School Boards provide two explanations for the firm cutoff mandatory maternity leave rules: they are necessary to maintain continuity of classroom instruction because it allows for the finding and hiring of qualified substitutes and because it protects the health of some teachers and unborn children who are physically incapable of performing some duties during later stages of pregnancy.

The first reason is not legitimate because the cutoff dates could be much later and still insure continuity, and continuity is sometimes worsened by the rule when teachers wish to finish a semester but are prevented by the firm cutoff dates. Thus they have no rational relationship to the valid state interest of preserving continuity of classroom instruction.

The rule sweeps too broadly to explain the second proffered reason because the ability to perform tasks during pregnancy is far more individualized. The Due Process Clause requires a more individualized determination, and administrative convenience alone is insufficient to justify the firm cutoff date.

The medical requirements and the requirement to not return to work until the next semester following birth are narrowly drawn and constitutional. The semester requirement serves the legitimate state interest of continuity in education. However the Cleveland rule requiring the mother to wait until the child reaches the age of three months prior to return is arbitrary and serves no reasonable objective.

Discussion.

The Court analyzed the two rules under the rational relationship test to determine Constitutionality under the Due Process Clause. Requirements that medical leave be obtained prior to returning to work and that the teacher return at the beginning of a semester where deemed rational, while the fixed cutoff dates for maternity leave were not.