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Cleveland Board of Education v. LaFleur

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Cleveland Board of Education v. LaFleur
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  • Jo Carol LaFleur was a teacher at Patrick Henry Jr. High School located in Cleveland, Ohio. During the time she was teaching she was also pregnant.
  • On March 12, 1971, LeFleur was informed that she would have to put her work on hold because the school board had made it a requirement for every teacher to take a mandatory maternity leave. The leave would be five months before the expected due date, the time would be without pay.
  • They want you in the office.
  • The school board ruled that a teacher could not return from their maternity leave until the beginning of the following semester or until the teacher had gotten a certificate from a physician proving they were in good medical health and that their newborn was at least 3 months old. Similarly, Ann Elizabeth Nelson was in the same situation. They were both forced to leave in March of 1971.
  • Constitutional Issue: Does a school board's policy of ending a teacher's employment during their fourth or fifth month of pregnancy violate the Due Process Clause of the Fifth and Fourteenth Amendment?
  • In a 7-2 decision, it was decided that that the school boards' regulation that required teachers to stop working after the fifth or fourth month of their pregnancy did violate the Fifth and Fourteenth Amendment. Justice Stewart stressed that the court protects individual choice in situations regarding "personal choice in matters of marriage and family life" (Oyez). He also argued that some rules were still needed to keep order because often times, teachers become incapable of working and teaching after a certain period in their pregnancy.
  • IMPACT: The case set precedent that overly controlling and restrictive maternity leave regulations in educational facilities violated the Fifth and Fourteenth Amendment. Additionally, it set precedent that discrimination against pregnant women and their ability to work would no longer be acceptable.
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