Cleveland Board of Education v. LaFleur

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.

Facts. Appellees’ brought suit challenging Appellant’s rule requiring every pregnant teacher to take maternity leave without pay at least five months prior to the expected birth of her child, with application filed two weeks prior to the date of departure. Despite their wishes to remain until the conclusion of the school year, they were forced to take leave in March. The babies were born in July and August respectively. The Appellees then brought suit claiming that they were deprived of their liberty right to teach without the protections provided them under the Due Process Clause of the Fourteenth Amendment.

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.

Dissent. Perplexed that the Court would use a Due Process Clause framework rather than a claim of sexual discrimination under the Equal Protection Clause, and under this alternative framework the regulation might pass muster. Furthermore, the lines drawn by the school board in this case is based on when medical evidence suggests that there may be some physical impairment, and therefore cannot find a judicial standard of measurement which says that the lines drawn by the school board is invalid.
Concurrence. Agrees in the decision, but believes that the case should not be decided on the ground that the mandatory maternity leave regulations impair any right to bear children or create an irrebuttable presumption. Would rather see an equal protection analysis of this case rather than that of a liberty right case under the Due Process Clause.

Discussion. This case, accompanied with Vlandis shows the difficulty an irrebuttable presumption in a regulation has in providing the due process rights guaranteed by the Fourteenth Amendment. It appears that if an irrebuttable presumption exists, and it is not proven to be conclusive by an overwhelming amount of evidence, that the regulation will fail under a due process analysis. This is the case even if it is a good faith effort to achieve a laudable goal. If there is a better method, especially a case-by-case determination of the ability to perform the required tasks, then that method should be entailed even if it is administratively inefficient.