Cleveland board of education v lafleur

CASE BRIEF 4

Case:

United States Supreme Court

Cleveland Board of Education v. La Fleur, 414 U.S. 632 (1974)

No. 12-777

Argued October 15,1973

Decided January 21,1974

Facts:

The Board of Education in Cleveland required that pregnant teachers in schools should take unpaid maternity leave fir five months before expected birth and return to school when the child is three months old. The teachers on unpaid leave were also not promised re-employment but could be given priority when there was a vacant position and were expected to bring a certificate from a doctor concerning their health. In 1970, Jo Carol LaFleur, who was teaching at Patrick Henry Junior High School, faced this rule of mandatory maternity leave against her wishes. Ann Elizabeth Nelson, another teacher from Cleveland teaching at Central Junior High School was dismissed under the same circumstances. The two teachers sued the Board of Education alleging that their rights had been violated regarding equal protection and due process according to the Fourteenth Amendment. In the Supreme Court, another plaintiff, Susan Cohen, joined the case. In its judgement, the Supreme Court ruled in favor of the teachers after finding that their rights to due process had been violated by the boards. It was declared that freedom to personal choice in relation to family and marriage life was protected under the Due Process Clause of Fourteenth Amendment.

Procedural history:

Jo Carol LaFleur and Ann Nelson filed cases in district courts to determine whether the Board of Education rules were constitutional. The courts held that the rules were constitutional. This decision was reversed by the United States Court of Appeal, Sixth Circuit, stating that the rules violated the Fourteenth Amendment on equal protection. Another Plaintiff, Susan Cohen, dismissed under the same circumstances. The district court in this case held that the rule was unconstitutional. The three plaintiffs took the case to the Supreme Court which stated that there was a violation of Fourteenth Amendment and that the rules were unconstitutional.

Issue:

Was there a violation of the Fourteenth Amendment’s clause of due process based on the mandatory termination of provisions of the schools’ maternity leave rules?

Holding:

The Supreme Court ruled in favor of the teachers, finding that the school boards violated the teachers’ rights of due process. It declared that freedom of personal choice regarding family and marriage life was a liberty protected under the clause of due process of the Fourteenth Amendment.

Judgement:

In marriage and family life, freedom of personal choice is a liberty protected under the Fourteenth Amendment’s clause of due process. This right protects people from unwarranted government intrusion especially where a person decides to bear children. Penalizing pregnant teachers for making a choice to bear children through restrictive maternity leave is a heavy burden on protected rights. The school rules on maternity affected basic civil rights contrary to the due process rights that requires that such rules do not arbitrarily or needlessly impinge on the liberty of the teachers.

Citation:

Www.oyez.org. (n.d.). Cleveland Board of Education v. LaFleur. Retrieved May 26, 2020, from https://www.oyez.org/cases/1973/72-777

Www.casebriefs.com. (n.d.). Cleveland Board of Education v. LaFleur. Retrieved May 26, 2020, from https://www.casebriefs.com/blog/law/family-law/family-law-keyed-to-weisberg/being-married-regulation-of-the-intact-members/cleveland-board-of-education-v-lafleur/

Www.law.cornell.edu. (n.d.). CLEVELAND BOARD OF EDUCATION et al., Petitioners, v. Jo Carol LaFLEUR et al. Susan COHEN, Petitioner, v. CHESTERFIELD COUNTY SCHOOL BOARD et al. Retrieved May 26, 2020, from https://www.law.cornell.edu/supremecourt/text/414/632

Supreme.justia.com. (n.d.). Cleveland Board of of Education v. LaFleur, 414 U.S. 632 (1974). Retrieved May 26, 2020, from https://supreme.justia.com/cases/federal/us/414/632/