## Facts

- A 16-year-old student attempted to enroll in a Texas public high school but was denied because his hair length violated a school board grooming rule applicable to male students.
- The rule limited male hair so it could not extend below the top of the collar, below the eyebrows, or cover the ears.
- After discussions with school officials failed, the student and his parent sued school administrators seeking declaratory and injunctive relief.
- The plaintiffs alleged the hair-length rule violated due process, equal protection, privacy, and First Amendment rights.
- After a multi-day trial, the federal district court held the denial of enrollment based on the rule violated due process and equal protection and enjoined enforcement.
- The court of appeals stayed the injunction pending appeal and later heard the case en banc.

## Issues

1. Whether a public high school student has a Fourteenth Amendment liberty interest in choosing hair length and style that requires heightened scrutiny of grooming regulations.
2. Whether a male-only hair-length rule violates the Equal Protection Clause.
3. Whether student hair length constitutes protected expression under the First Amendment or falls within a constitutionally protected zone of privacy limiting school regulation.

## Decision

- The en banc court reversed the district court and upheld the hair-length regulation.
- The court held that a student’s preferred hair length is not a fundamental right protected as a substantive due process liberty interest.
- The court rejected the First Amendment claim, finding the hair choice insufficiently communicative to warrant heightened protection.
- The court rejected the equal protection challenge to sex-differentiated grooming standards under a deferential standard of review.
- The injunction against enforcement was dissolved.

## Legal Principles

- Personal preference in hair length for public school students is not a fundamental constitutional right triggering strict scrutiny.
- Grooming regulation in public schools is generally within the traditional authority of state and local educational officials, and federal courts should not substitute their judgment absent a clear constitutional violation.
- Where no fundamental right or suspect classification is implicated, school grooming rules are evaluated under a deferential, rational-relationship standard.
- A school need not prove actual or likely “substantial disruption” to justify a grooming code when the challenged conduct is not treated as protected expression comparable to recognized symbolic speech.

## Conclusion

The court upheld a public high school’s male hair-length regulation, concluding that student grooming choices do not constitute a fundamental right or protected expression in this context and that sex-differentiated grooming standards and enforcement decisions are generally sustained if reasonably related to legitimate school interests.


Karr v. Schmidt, 460 F.2d 609 (5th Cir. 1972) (en banc)