Cleveland Board of Education v. Lafleur 414 U.S. 632 (1974)
CLEVELAND BOARD OF EDUCATION v. LAFLEUR 414 U.S. 632 (1974)
The Cleveland school board required a pregnant school teacher to take maternity leave, without pay, for five months before the expected birth of her child. A Virginia county school board imposed a similar four-month leave requirement. The Supreme Court, 7–2, held these rules unconstitutional. Justice potter stewart, for the majority, invoked the irrebuttable presumptions doctrine. The school boards, by assuming the unfitness of pregnant teachers during the mandatory leave periods, had denied teachers individualized hearings on the question of their fitness, in violation of the guarantee of procedural due process. Justice william o. douglas concurred in the result, without opinion. Justice lewis f. powell rejected the irrebuttable presumptions ground as an equal protection argument in disguise, but concluded that the boards' rules lacked rationality and denied equal protection. Justice william h. rehnquist, for the dissenters, aptly characterized the irrebuttable presumptions doctrine as "in the last analysis nothing less than an attack upon the very notion of lawmaking itself."
Kenneth L. Karst
(1986)