Gfell v. RickelmanGfell v. Rickelman
MEMORANDUM OPINION AND ORDER
In December, 1969, Edward Bruce Gfell was suspended from West Geauga High School for failing to comply with the Dress Code of said school. In particular, Edward B. Gfell was suspended from school for having his hair cover his ears in violation of the Dress Code. Shortly after his suspension, Edward complied with the Dress Code by having his hair cut. He then was allowed back into school. On December 18, 1969, the plaintiff, uрon behalf of his son, filed this suit seeking injunctive relief and a declaratory judgment that the Dress Code in regard to hair was null and void as repugnant to the United States Constitution. On the same day, the plaintiff moved for a preliminary injunction. Pursuant to
The Court finds that Edward Bruce Gfell has not been deprived of аny constitutional rights with respect to the promulgation and enforcement of the hair length provision of the Dress Code. The Court further finds that the Dress Code, in regard to the hair length of male students, is not unreasonable, arbitrary, nor capricious. Rather, there is, and the Court so finds, a rational basis for this provision of the Dress Code. See Jackson v. Dorrier,
“Among the things a student is supposed to learn at school (at leаst, such is my idea) is a sense of discipline. Of course, rules cannot be made by authorities for the sake of making them but they should possess considerable leeway in promulgating regulations for the proper conduct of students. Courts should uphold them where there is any rational basis for the questioned *366 rule. All that is necessary is a reasonable connection of the rule with the proper operation of the schools. By accepting an education at public expense pupils at the elementary or high school level subject themselves to considerable discretion on the part of school authorities as to the manner in which they deport themselves. Those who run public schools should be the judges in such matters, not the courts. The quicker judges get out of the business of running schools the better. * * * Except in extreme cases the judgment of school officials should be final in applying a regulation to an individual case.” (Emphasis added.)
In the following respects, the provision of the Dress Codе on the hair length of male students has a reasonable connection to the proper operation of West Gеauga High School:
1. The provision of the Dress Code dealing with the hair length of male students tends to maintain discipline and order in the school. In this regard, it is significant to note that there have been disturbances at West Geauga High School which have been precipitated by the wearing of long hair by male students. The incidents involving Evan Rhodes and John Rose attest to this fact.
2. The provision of the Dress Code which concerns the length of hair of male students has a reasonable relationship to the prevеntion of safety hazards. In particular, long hair creates a safety hazard in the industrial arts courses. Approximately, one-third of the male students in West Geauga High School are enrolled in such courses.
3. The Dress Code in regard to the length of hair of male students has a reasonable relationship to the athletics program of West Geauga High School. In this regard, among оther things, the high school athletic association to which West Geauga High School belongs prohibits the wearing of long hair for thоse competing in wrestling.
4. The provision of the Dress Code which regulates the hair length of male students has a reasonable rеlationship to the teaching of proper grooming, discipline and etiquette. It is well to remember that in addition to its educаtional function, the school’s mission is also to teach proper discipline, etiquette and grooming. The provision in question provides such a vehicle. Moreover, it is worthy of emphasis that the grooming standards in the Dress Code were promulgated by the student body of West Geauga High School with the approval of the school administration. This promulgation of the Dress Code by the student body dispels any contention of arbitrariness or of capriciousness. Who is better able to judge the proper standards of dress and of grooming for students than students themselves ?
Notwithstanding the above findings and in addition thereto, the Court finds that the officials of West Geauga High School acted within the proper scope of their authority in enforcing the Dress Code. They have еxercised their judgment in regard to the operation of West Geauga High School within constitutional limitations. The enforcement of the Dress Code and, in particular, the provision concerning the length of hair of male students, in no way interferes with the cоnstitutional rights and prerogatives of the students of West Geauga High School. As noted previously, in addition to the educational funсtion, the school’s mission is also to teach discipline, etiquette and grooming. To these ends, the Dress Code has a real and reasonable relationship.
Courts, moreover, should ever be cautious of interfering with the proper mission and function of the educational system. Such interference could dilute the authority of the educational system and in turn, undermine the effeсtiveness of the schoolmaster and teacher. We have become a great nation because of the genius оf the American educational system. Judicial interference with the *367 proper mission and function of the educational system could sound the death knell of this system which has served this country so well for so long.
This cause is dismissed.
It is so ordered.