## Facts

- Public school boards in Cleveland, Ohio and Chesterfield County, Virginia adopted mandatory maternity-leave rules for pregnant teachers.
- Cleveland required a pregnant teacher to begin unpaid leave five months before expected childbirth and barred return until the next regular semester after the child was three months old.
- Chesterfield County required leave at least four months before anticipated birth, required six months’ notice of pregnancy, and conditioned reemployment on medical certification of fitness.
- All policies relied on fixed dates rather than individualized determinations of a teacher’s ability to work, though medical certification was relevant to return.
- Jo Carol LaFleur and Ann Elizabeth Nelson sought to continue teaching through the end of the school year but were required to leave under the Cleveland rule.
- Susan Cohen’s physician believed she could continue teaching, but she was denied an extension under the Chesterfield County rule.
- The teachers sued under 42 U.S.C. § 1983, alleging violations of the Fourteenth Amendment.
- In the Cleveland case, the district court upheld the policy and the Sixth Circuit reversed.
- In the Chesterfield County case, the district court invalidated the rule; the Fourth Circuit initially affirmed but later upheld it en banc.
- The Supreme Court granted certiorari and consolidated the cases.

## Issues

1. Whether mandatory maternity-leave rules requiring teachers to stop working at fixed points before childbirth violate the Due Process Clause of the Fourteenth Amendment.
2. Whether Cleveland’s rule barring return until the child is at least three months old and until the next semester violates the Due Process Clause of the Fourteenth Amendment.

## Decision

- The Court held that the fixed pre-birth leave requirements in both systems violated the Fourteenth Amendment’s Due Process Clause.
- The Court held that Cleveland’s postpartum return restriction also violated due process.
- The Court reasoned that the rules were not sufficiently related to asserted interests such as continuity of instruction and administrative predictability, given existing advance-notice requirements.
- The Court concluded the rules imposed conclusive presumptions about pregnant teachers’ incapacity and postpartum unfitness, without individualized assessment.
- Justice Rehnquist dissented, joined by Chief Justice Burger, urging greater deference to school board policy judgments.

## Legal Principles

- The Due Process Clause protects liberty interests in personal decisions concerning marriage and family life, and the government may not impose needless, arbitrary burdens on those interests through employment rules.
- A public employer violates due process when it uses fixed, non-individualized maternity leave cutoffs that function as conclusive presumptions of incapacity.
- Administrative convenience alone cannot justify rules that foreclose individualized determinations where individualized assessment is feasible.
- Postpartum return restrictions that presume unfitness despite medical certification, and that lack a rational connection to continuity-of-instruction goals, are arbitrary and unconstitutional.

## Conclusion

The Court invalidated mandatory maternity-leave policies that forced pregnant teachers to leave at fixed pre-birth dates and, in Cleveland, delayed return until a set postpartum milestone, holding that such conclusive presumptions were arbitrary and violated due process.


Cleveland Bd. of Educ. v. LaFleur, 414 U.S. 632 (1974)