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Keywords

lawsuittrialburden of proofregulationdue processjudicial review

appealtestimonyplealeaseregulationappellee

Related Cases

Karr v. Schmidt, 460 F.2d 609

Facts

Chesley Karr, a sixteen-year-old student at Coronado High School in El Paso, Texas, was denied enrollment for his junior year due to a school board regulation that limited the length of male students' hair. After unsuccessful attempts to resolve the issue with school officials, Karr filed a lawsuit seeking injunctive and declaratory relief. The district court ruled in Karr's favor, concluding that the hair-length regulation violated his due process and equal protection rights under the Federal Constitution.

Appellee Chesley Karr is a sixteen-year-old student at Coronado High School in El Paso, Texas. On August 12, 1970, Karr attempted to enroll for his junior year at that school but was not permitted to do so because he was in violation of a school board regulation limiting the length of male students' hair.

Issue

Does a high school student have a constitutional right to wear his hair in a length and style of his choosing, and does the school board's hair-length regulation violate the student's rights?

Is there a constitutionally protected right to wear one's hair in a public high school in the length and style that suits the wearer?

Rule

The court held that there is no constitutionally protected right for students to wear their hair in a particular style or length in public schools. Regulations that do not affect fundamental freedoms are subject to a less rigorous standard of judicial review, requiring only that the regulation is reasonably intended to accomplish a constitutionally permissible state objective. The burden of proof lies with the challenger to demonstrate that the regulation is arbitrary.

There is no constitutionally protected right to wear one's hair in a public high school in the length and style that suits the wearer. (Per Morgan, Circuit Judge, with six circuit judges concurring and one circuit judge specially concurring.)

Analysis

The court analyzed the evidence presented during the trial, noting that the school board's regulation aimed to prevent classroom distractions and maintain discipline. The district court had found that the regulation was unreasonable, but the appellate court determined that the school board's objectives were legitimate and that the regulation met the minimum rationality test. The court emphasized that the federal judiciary should not intervene in school affairs unless fundamental rights are at stake.

In view of testimony regarding objectives in promulgating hair regulation, it was clear error for district court to conclude that school board regulation failed to meet the minimum test of rationality that was properly applicable.

Conclusion

The appellate court reversed the district court's decision, holding that the hair-length regulation was constitutionally valid and that Karr's asserted right to wear his hair long was not protected by the Constitution.

The conclusion is inescapable that this paragraph was intended to delimit the outer reach of the court's holding. We read this language as indicating that the right to style one's hair as one pleases in the public schools does not inherit the protection of the First Amendment.

Who won?

The prevailing party in this case was the school board, as the appellate court reversed the district court's ruling in favor of Karr. The court found that the school board's regulation was rationally related to legitimate educational objectives, such as maintaining discipline and preventing distractions in the classroom. The court emphasized the importance of allowing local school authorities to manage their own regulations without federal interference, particularly when fundamental rights are not implicated.

The appeal from the district court's judgment is now before this court on the merits. Believing, as did Mr. Justice Black, that appellee Karr's asserted right to be free of school regulations governing the length of his hair is one that is not cognizable in federal courts, we reverse with direction that the case be dismissed for failure to state a claim for which relief can be granted.

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