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
- Whether mandatory maternity-leave rules requiring teachers to stop working at fixed points before childbirth violate the Due Process Clause of the Fourteenth Amendment.
- 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.