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Keywords

damagesappealcompliance

plaintiff

Related Cases

Long v. Zopp, 476 F.2d 180

Facts

A high school student challenged the denial of his football 'letter' due to the length of his hair. The football coach at Greenbrier East High School enforced a 'hair code' that applied throughout the school year, not just during the football season. The student earned his 'letter' during the season but allowed his hair to grow longer afterward, leading to the denial of his 'letter' and an invitation to the athletics banquet. The District Court dismissed his action, prompting an appeal.

The football coach at Greenbrier East High School…decreed that all members of the football squad…should observe a 'hair code' prescribed by him, not merely during football season, but throughout the school year, under penalty of being denied their 'letter' for participation as a member of the team.

Issue

Is it constitutionally permissible for public schools to impose 'hair codes' on students participating in school-controlled activities, including athletics?

Is it constitutionally permissible for public schools to impose 'hair codes' on their students participating in school-controlled activities, including athletics?

Rule

The doctrine established in Massie v. Henry holds that public schools cannot impose 'hair codes' on students, as such codes are unconstitutional. This principle applies to all school-controlled activities, including athletic programs, and awards earned cannot be used to enforce compliance with such codes without a compelling necessity.

The doctrine that it is constitutionally impermissible for public schools to impose 'hair codes' on their students is applicable to all school-controlled activities, including school athletic programs.

Analysis

In applying the rule from Massie v. Henry, the court found that the football coach's enforcement of the 'hair code' beyond the football season was unconstitutional. The student had complied with the code during the season and earned his 'letter', but the subsequent enforcement of the code in the off-season lacked justification. The court reasoned that there was no compelling necessity for the code to extend beyond the season, thus violating the student's rights.

Assuming arguendo that there might be some hygienic or other reason to support a 'hair code', as promulgated by the football coach during football season, such reason would plainly not justify the enforcement of the code after the football season had ended.

Conclusion

The court reversed the District Court's decision, ruling that the denial of the student's 'letter' was unlawful and entitled him to injunctive relief, but not monetary damages.

We reverse.

Who won?

The student prevailed in this case as the court found that the enforcement of the 'hair code' by the football coach was unconstitutional. The court emphasized that the denial of the 'letter' was not justified after the football season had ended, and the student was entitled to injunctive relief to rectify the situation.

The plaintiff is entitled to injunctive relief.

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