Brief Fact Summary. Appellees La Fleur and Nelson were required by the Appellants Cleveland and Chesterfield School Districts to take maternity leave once they reached the fifth month of their pregnancy. They later filed suit claiming that they were deprived of their liberty rights without due process of law in violation of the Fourteenth Amendment because of the irrebuttable presumption made in the regulation that they were unable to perform their teaching duties once they reached the fifth month of pregnancy.
Synopsis of Rule of Law. A good-faith attempt to achieve a laudable goal cannot pass muster under the Due Process Clause of the Fourteenth Amendment if it employs irrebuttable presumptions.
Issue. Whether the interests advanced in support of the rules of the Cleveland and Chesterfield County School Boards can justify the particular procedures they have adopted?
Held. No. The arbitrary cut-off dates embodied in the mandatory leave rules have no rational relationship to the valid state interest of preserving continuity of instruction. As long as the teacher is required to give substantial advance notice of her condition the choice of firm dates later in pregnancy would serve the boards’ objectives just as well, while imposing a far lesser burden on the women’s exercise of constitutionally protected freedom. The rules in this case sweep too broadly because there was no individualized determination by the teacher’s doctor or the school board’s doctor as to any particular teacher’s ability to continue teaching. The rules, instead, contain an irrebuttable presumption of physical incompetence, and that presumption applies even when the medical evidence shows the contrary to be true. The Court also holds that administrative convenience alone is insufficient to validate an otherwise obvious violation of due process law.
Indeed, one might fairly say of the Bill of Rights in general, and the Due Process Clause in particular, that they were designed to protect the fragile values of a vulnerable citizenry from the overbearing concern for efficiency and efficacy that may characterize praiseworthy government officials no less, and perhaps more, than mediocre ones.View Full Point of Law