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Dunham v. Pulsifer, 312 F.Supp. 411

Facts

This case involves high school students Steven Dunham, Prentiss Smith, and Paul B. Weber, who sought to enjoin the enforcement of an athletic grooming code adopted by the Brattleboro Union High School. The code mandated specific haircuts for male athletes, which led to the plaintiffs' dismissal from the tennis team for non-compliance. The plaintiffs argued that the grooming code violated their Fourteenth Amendment right to equal protection under the law, as it imposed arbitrary restrictions without substantial justification.

On December 16, 1969, pursuant to number o above, the School Board enacted the following athletic code: In order to enhance esprit de corps, prevent adverse public reaction, prevent dissension on teams, and for the general welfare of teams and participants the following regulations governing dress and grooming for pupils participating in and traveling to and from interscholastic athletic activities are in effect: 1. Whenever eating and not traveling in team uniform, male athletes shall wear jacket and tie. 2. For males, hair must be cut tapered in the back and on sides of the head with no hair over the collar. Sideburns must be no lower than the earlobe and trimmed.

Issue

Whether the athletic grooming code enforced by the Brattleboro Union High School violates the plaintiffs' right to equal protection under the Fourteenth Amendment.

Whether the athletic grooming code enforced by the Brattleboro Union High School violates the plaintiffs' right to equal protection under the Fourteenth Amendment.

Rule

The Equal Protection Clause of the Fourteenth Amendment prohibits state actions that deny equal protection of the laws. A classification made by a state must be justified under the applicable standard of review, which varies depending on whether fundamental rights are implicated. If a classification infringes upon a fundamental right, it must be justified by a compelling governmental interest.

The equal protection clause is the Constitution's check on the generous latitude given legislative institutions to regulate by classification the citizens they represent. U.S.C.A.Const. Amend. 14.

Analysis

The court analyzed the grooming code under the active standard of review due to its infringement on the fundamental right of personal appearance. The justifications provided by the school, including performance, discipline, and conformity, were found to lack credible evidence supporting their necessity. The court concluded that the grooming code was arbitrary and did not serve a compelling state interest, thus failing to meet the constitutional requirements for such classifications.

The evidence shows no reasonable relation between the regulatory classification created by the dress code and the permissible objectives of a high school tennis program.

Conclusion

The court held that the athletic grooming code was unconstitutional and ordered the reinstatement of the plaintiffs to the tennis team, permanently enjoining the school from enforcing the code against them.

High school athletic grooming code requiring males to wear hair tapered to back and on sides of head with no hair over collar, and with sideburns no lower than ear lobe and trimmed was unconstitutional, and asserted justifications based on performance, dissension on teams, discipline and conformity and uniformity were not substantial justification for infringement on fundamental right. U.S.C.A.Const. Amends. 1, 9, 14.

Who won?

The plaintiffs, Steven Dunham, Prentiss Smith, and Paul B. Weber, prevailed in their action against the Brattleboro Union High School. The court found that the grooming code imposed by the school was unconstitutional as it violated their right to equal protection under the Fourteenth Amendment. The court determined that the justifications for the code were insufficient and arbitrary, leading to the conclusion that the plaintiffs should be reinstated to the tennis team.

The plaintiffs, Steven Dunham, Prentiss Smith, and Paul B. Weber, prevailed in their action against the Brattleboro Union High School. The court found that the grooming code imposed by the school was unconstitutional as it violated their right to equal protection under the Fourteenth Amendment.

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