## Facts

- Tyler Junior College, a Texas public junior college, adopted a comprehensive student dress code shortly before the Fall 1970 semester.
- The code included a provision regulating male students’ hair length and style.
- Joe Richard Lansdale and two other prospective students attempted to register but were refused solely because their hair did not conform to the hair-length provision.
- The students sued college officials and the college under 42 U.S.C. § 1983, invoking federal jurisdiction under 28 U.S.C. § 1343, and sought class-wide relief.
- The students alleged the hair-length rule, as enforced to bar registration, was arbitrary and unreasonable and violated the Fourteenth Amendment.
- The college asserted the rule furthered a healthy educational environment and campus order and discipline.

## Issues

1. Whether a public junior college’s hair-length regulation for male students, enforced to deny registration, violates the Fourteenth Amendment.
2. What level of judicial scrutiny and evidentiary showing should govern constitutional challenges to public school or college grooming regulations.

## Decision

- The Fifth Circuit, sitting en banc, affirmed the district court’s permanent injunction preventing enforcement of the hair-length regulation against the plaintiffs.
- The affirmance rested on multiple concurring opinions; no single rationale commanded a majority of the en banc court.
- The court’s separate writings reflected disagreement over the proper doctrinal basis (e.g., liberty, equal protection, and the weight given to institutional justifications) and over how much deference was owed to school administrators.

## Legal Principles

- A fractured en banc affirmance may confirm relief on an as-applied record while providing limited controlling guidance on a single constitutional theory.
- In evaluating grooming rules in public education, courts may reject asserted institutional justifications when the record does not show a non-arbitrary basis for excluding students from enrollment.
- Administrative claims about discipline, order, hygiene, or educational environment may be treated with skepticism when used as case-specific factual predicates to justify intrusive appearance restrictions, particularly for older students in higher education.

## Conclusion

The en banc court left in place a permanent injunction against a public junior college’s enforcement of a male hair-length rule to deny registration, concluding—through divided and separate opinions—that the regulation was not sufficiently justified on the record to withstand Fourteenth Amendment challenge as applied to the plaintiffs.


Lansdale v. Tyler Junior Coll., 470 F.2d 659 (5th Cir. 1972) (en banc)