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CLEVELAND BOARD OF EDUCATION v. LAFLEUR

CLEVELAND BOARD OF EDUCATION v. LAFLEUR. Sonia Torres EDLP 6110-60 Professor Reid. William Paterson University Cohort 14. TITLE AND CITATION:. CITATION ( 414 U.S. 632,94 S. Ct. 791,39 L. Ed. 2d 52,1974 U.S. LEVEL OF COURT OR TYPE (Supreme Court) Case Basics :

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CLEVELAND BOARD OF EDUCATION v. LAFLEUR

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  1. CLEVELAND BOARD OF EDUCATION v. LAFLEUR Sonia Torres EDLP 6110-60 Professor Reid William Paterson University Cohort 14

  2. TITLE AND CITATION: • CITATION (414 U.S. 632,94 S. Ct. 791,39 L. Ed. 2d 52,1974 U.S. • LEVEL OF COURT OR TYPE (Supreme Court) • Case Basics: • Docket No. 72-777 • Petitioner - Cleveland Board of Education • Respondent - Jo Carol LaFleur • Consolidation - No. 72-1129, Cohen v. Chesterfield County School Board

  3. LEVEL • Brief Fact Summary. Teachers brought suit under two state laws placing fixed cutoff dates for mandatory maternity leave and establishing set requirements prior to return. • Synopsis of Rule of Law. The Due Process Clause of the Fourteenth Amendment requires such rules must not needlessly, arbitrarily, or capriciously impinge upon the vital area of a teacher’s constitutional liberty.

  4. FACTS Carol Jo LaFleur was a teacher at Patrick Henry Junior High School in Cleveland, Ohio. She was forced to discontinue her duties on March 12, 1971 because the Cleveland School Board required every teacher to take maternity leave without pay five months before the expected date of birth. The board also ruled that a teacher could not return from maternity leave until 1) the next school semester began, 2) the teacher obtained a certificate from her physician showing good medical health, and 3) the newborn child was three months old.

  5. ISSUE • WHAT WAS DONE OR WASN’T DONE • LaFleur did not wish to take an unpaid maternity leave; she wanted to continue teaching until the end of the school year. Because of the mandatory maternity leave rule, however, she was required to.

  6. HOLDING • FOUNDED OR UNFOUNDED

  7. LEGAL DOCTRINE • Vote was 7-2 majority • Justice Potter Stewart held that the school boards’ regulations requiring pregnant teachers to stop working after the fifth month of their pregnancies violated the Fourteenth Amendment’s due process clause. 

  8. SIGNIFICANCE • WHY WAS THIS CASE SIGNIFICANT? • WHAT DID IT CHANGE? • This decision was a major step in protecting the rights of teachers, especially female teachers, from unfair prejudicial rules which would keep them from the profession of teaching. This decision also plays a critical role in the professionalization of teaching by protecting all teachers from arbitrary, political regulations which serve no pedagogical function. The case of LaFleur can also be seen as a building block for current family leave laws, which help to ensure that all people can keep their professions without giving up the ability, and the means, to have a family.

  9. http://www.nytimes.com/2014/12/11/opinion/the-supreme-court-and-rights-for-pregnant-workers.html?_r=0http://www.nytimes.com/2014/12/11/opinion/the-supreme-court-and-rights-for-pregnant-workers.html?_r=0

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