Uniforms in Public Schools and the First Amendment: A Constitutional Analysis
Mitchell, Harold W
Debates about the use of school uniforms in public schools have received much attention in the last few years. Many educational stakeholders believe that uniforms may curb negative behaviors associated with student dress such as teasing, absenteeism, tardiness, gang-related activity, and school violence. One primary argument espoused by opponents is that uniforms interfere with students’ right to choose their dress-a violation of students’ First Amendment right to free speech. This article describes selected constitutional issues related to the use of school uniforms with a focus on the First Amendment and concludes with implications for uniform policies in public schools.
Public and private schools in the United States have always had dress code polices (Del Campo & Del Campo, 1998) with uniforms being generally the purview of private schools, especially parochial schools (Joseph, 1986). Debates about the use of school uniforms in public schools have received much attention in the last few years especially when former President Bill Clinton took a stand for uniforms in public schools and signed an executive order to send all U.S. school districts a manual on ways to encourage the use of uniforms (Del Campo & Del Campo, 1998; U.S. Department of Education, 1996). Many school stakeholders-students, teachers, staff, families, community members, and elected officials-believe that uniforms may curb negative behaviors associated with student dress such as teasing, absenteeism, tardiness, gang-related activity, and school violence (Holloman, LaPoint, Alleyne, Palmer, & Sanders-Phillips, 1996; Portner, 1998). One primary argument espoused by opponents of uniforms is that public schools’ interfere with students’ right to choose their dress-a violation of students’ First Amendment right of free speech (Jahn, 1998). The purpose of this article is to describe some constitutional issues related to the use of school uniforms in public schools. The article includes: (a) a literature review highlighting positions for and against uniforms in public schools; (b) description of the First Amendment as related to the use of uniforms in public schools, including determinative factors; (c) limitations of the First Amendment on the rights of minors; and (d) implications for uniform policies in public schools.
REVIEW OF THE LITERATURE
While research and reports have been, published on the use of dress codes and uniforms in public schools (LaPoint, Alleyne, Mitchell, & Lee, 2003; Lopez, 2003), this review will highlight the positions of proponents and opponents of uniforms in public schools. Proponents of uniforms believe that uniforms can alleviate many of the dress-related behavior problems being experienced in public schools-generally promoting student health, safety, and varying academic related outcomes (LaPoint et al., 2003; LaPomt, Holloman, & Alleyne, 1992). Some proponents believe that uniforms reduce negative peer pressure (e.g., teasing, bullying) and other victimization (Carroll, 1994; LaPoint et al., 2003; Scherer, 1991; U.S. Department of Education, 1996), decreasing gang activity and fighting (Kennedy, 1995; Loesch, 1995). Proponents also believe that uniforms can increase positive student attitudes toward school and its educational goals (LaPoint et al., 2003; Workman & Johnson, 1994). Last, proponents of uniforms believe that uniforms can increase attendance rates, lower suspension rates, and decrease substance abuse rates (Gursky, 1996).
While there are proponents of uniform use in public schools, opposition to uniforms exists. The first reason for opposition is that uniforms are believed to restrict student, parent, and family rights for freedom of expression in dress (Caruso, 1996; Portner, 1998). This issue has relevance to some youth of color especially those in urban areas. Dress has cultural and ethnic dimensions (LaPoint et al., 2003). Some youth of color, their parents, families, and community members may view dress codes and uniforms as restrictions on students’ cultural expressions of dress. The second reason for opposition is that uniforms restrict youth engagement in normal developmental tasks of identity experimentation with dress (Portner, 1998). Third, it is believed that uniforms contribute to punitive zero tolerance in student discipline policies (Skiba, 2001). Opponents also believe that uniforms represent and encourage the intrusion of local and state policies in the private lives of students and parents (Jahn, 1998; Lane, Swartz, Richardson, & Van Berkum, 1994). Moreover, some opponents emphasize the paucity of empirical research on the effects of uniforms on academic achievement and prosocial behavior (Brunsma & Rockquemore, 1998; Del Campo & Del Campo, 1998).
Critics of the uniform policies, including the American Civil Liberties Union, accuse schools of taking a simplistic approach to school violence. The largest opposition to school uniforms, however, is not cost or style, but constitutionality. For additional reviews of legal issues relating to dress codes and uniforms, see DeMitchell, Fossey, and Cobb (2000), McCarthy (2001), Starr (2000), and Taylor (2001).
THE FIRST AMENDMENT AND THE CONSTITUTIONALITY OF SCHOOL UNIFORMS
The First Amendment provides that “Congress shall make no law abridging the freedom of speech…” (U.S. Const. Amend. I). Further, the freedom of speech protection was extended to state and local governments through the Fourteenth Amendment (U.S. Const. Amend. XIV). There are several interpretations of the First Amendment. Supreme Court justices Hugo Black and William Douglas supported the idea that the First Amendment right speaks in absolute terms; that is, the First Amendment protects all speech (Barbarosh, 1995). However, regardless of the language of the Constitution, the highest court has never interpreted the Amendment in a solely textual sense.
The Court has set forth various categories of speech and regulations to aid in determining whether a governmental regulation infringes on constitutionally protected speech (Farber, 1980; Nowak & Rotunda, 1995). Consequently, depending on which category is being addressed, different tests are applied to determine the scope of permissible restraints on that type of speech. Hence, an analysis of dress codes in the public schools must first consider whether the regulated speech receives protection and then examine the scope of that protection for public school students (Spence v. Washington, 1974; Tinker v. Des Moines Indep. Seh. Dist., 1969).
In determining whether school uniforms violate an individual’s First Amendment rights, the Supreme Court must examine several determinative factors: (a) type of speech (e.g., pure vs. symbolic); (b) type of restriction (i.e., Spence Test); (c) the O’Brien analysis; and (d) the surrounding context.
Types of Speech: Pure and Symbolic Speech
To determine the validity of governmental regulations concerning speech, the Court has recognized two different types of speech: pure speech and symbolic speech. Courts maintain that all speech classified as pure or verbal speech receives some type of First Amendment protection (Tinker v. Des Moines Indep. Seh. Dist., 1969). Some categories of pure speech, however, receive less protection, such as obscenity or defamatory words (Gertz v. Robert Welch, Inc., 1973; Miller v. California, 1973; Tinker v. Des Moines Indep. Sch. Dist., 1969).
In defining symbolic speech, the courts generally apply a two-pronged test: (a) was there an intent to convey a particular message and (b) was there a great likelihood that the message would be understood by those who viewed it. Additionally, courts consider a nonverbal act symbolic speech if it contains some communicative value (Tiersma, 1993). Thus, conduct, and not solely words, can communicate self-expression; as a result, the courts protect some forms of conduct as expressive symbolic speech within the meaning of the First Amendment (Texas v. Johnson, 1989).
The individual selection of dress satisfies both prongs of the test; therefore, it constitutes symbolic speech. Studies show that dress is conduct where it conveys messages about the self and suggests countless qualities about identity, attitudes, values, and moods (Horn & Gurel, 1981; Kaiser, 1996). Studies also indicate that individuals’ dress communicates nonverbally to others and that this can affect the way others view individuals, and quite possibly, the way that individuals view themselves (Eicher, Evenson, & Lutz, 2000; Vicary, 1988).
Types of Restrictions (The Spence Test)
In Spence v. Washington (1974), the Supreme Court articulated two types of restrictions, which, if met, qualify as symbolic speech worthy of First Amendment protection, content-based and content-neutral restrictions. Content-based regulations involve the elimination of a specific conduct by prohibiting the expression of one viewpoint. For example, in Boos v. Barry (1996), three individuals wanted to display signs critical of the governments of the Soviet Union and Nicaragua on the public sidewalks, and to congregate with other persons, within 500 feet of the embassies of those governments in Washington, DC. However, a provision of the District of Columbia Code made it unlawful (a) to display within 500 feet of a foreign embassy any sign tending to bring a foreign government into public odium or public disrepute, or (b) to congregate within 500 feet of any foreign embassy and to refuse to disperse after having been ordered so to do by the police. These protesters and a political activist filed suit in the United States District Court for the District of Columbia against the Mayor of the District of Columbia and other law enforcement officials, seeking declaratory and injunctive relief on the ground that the provision violated the Federal Constitution’s First and Fourteenth Amendments. The United States Supreme Court held that the clause was a content-based restriction because the prohibition was targeted towards one and not all forms of speech.
Courts hold content-based restrictions to the strictest scrutiny (I’exas v. Johnson, 1989). The strict scrutiny test requires the government to show that the regulation is necessary to serve a “compelling state interest” and is “narrowly drawn to achieve that end” (Widmar v. Vincent, 1981). Considering the content distinctions the Court uses to analyze the constitutionality of regulations on expression, it is unlikely that the Court will consider a total ban on expression through dress, a content-based regulation. Unlike the situation in Boos cited earlier, school uniform statutes do not prohibit certain categories of dress; rather, they completely ban all choice in dress. Thus, the statute is not selecting between viewpoints.
Content-neutral regulations are those that prohibit speech to avoid negative behavior unconnected to the content of the speech. Content-neutral regulations often interfere with speech by regulating the time, place, and manner of speech. This type of regulation must meet a substantial government purpose and be narrowly tailored to meet that purpose. Because school uniforms permit a complete ban and do not select between viewpoints, courts should consider the policy to be content-neutral. A regulation whose purpose is unrelated to the content of the expression is deemed content-neutral, despite an incidental effect on some speakers or messages but not others (City of Cincinnati v. Discovery Network, Inc., 1993). As long as such a regulation is uniformly applied, the Supreme Court sees the regulation as significantly less threatening to the First Amendment (Farber & Nowak, 1984). Therefore, school uniform statutes can be said to satisfy the Spence test. Thus, there is symbolic speech protected by the First Amendment. Moreover, based on the Spence test, school uniform statutes fall into the category of content-neutral regulation (Spence v. Washington, 1974). The next step requires a determination of whether the government’s regulation of speech, which seeks to avoid some evil unconnected with the speech’s content, constitutes a violation of students’ First Amendment right to free speech (R.A.V. v. City of St. Paul, 1992).
The O’Brien Analysis
The Supreme Court in United States v. O’Brien (1968) delineated a four-pronged test to determine whether a content-neutral governmental invasion of the right to free expression violates the First Amendment. In United States v. O’Brien, the defendant was convicted and sentenced after he publicly burned his registration certificate in an attempt to influence others to adopt his antiwar beliefs. The amendment that the defendant allegedly violated prohibited the knowing destruction of Selective Service registration certificates. he argued that the amendment was unconstitutional because his conduct was symbolic speech protected by the First Amendment. The court held a sufficient governmental interest to justify the conviction because of the government’s substantial interest in assuring the continuing availability of issued Selective Service certificates, because the amendment condemned only the independent noncommunicative impact of conduct within its reach, and because the noncommunicative impact of cross-petitioner’s act frustrated the government’s interest. Further, an otherwise constitutional statute would not be struck down on the basis of an alleged illicit legislative motive. The Supreme Court rejected the view that the First Amendment would protect anyone engaged in any conduct intended to convey a message.
The Court set out the following standards, now known as the O’Brien Test for analyzing statutes regulating symbolic speech. A regulation will be justified if: (a) it is within the government’s interest, (b) it furthers an important or substantial government interest, (c) the government interest is unrelated to the suppression of free expression, and (d) the incidental restriction on First Amendment rights is no greater than necessary to further that interest (United States v. O’Brien, 1968).
The first prong of the O’Brien standard requires that the regulation be sufficiently justified within the government’s interest (United States v. O’Brien, 1968). The main argument of this prong is made by school districts. Districts contend that uniform implementation increases the public safety or welfare of schoolchildren; therefore, the application of uniforms are within the government’s interest. second, the regulation must further an important or substantial government interest. The state’s interest in reducing gang violence is indeed substantial, especially because schools are supposed to be neutral environments conducive to learning. States’ efforts to preserve and protect their educational processes are undoubtedly important to society (Dawson v. Hillsborough City, Fla. Seh. Bd., 1971). Thus, the governmental interest in reducing gang violence satisfies one portion of the second prong of the O’Brien test. The third prong of the O’Brien test asks whether the regulation is unrelated to suppression of free expression (Polacheck, 1994). The school uniform policy is designed to eliminate various types of in-school behavior from gang affiliation to overall youth violence. The policy is not intended to trample the rights of student’s individuality or freedom of expression. The fourth prong of the O’Brien test requires that the incidental restriction on First Amendment rights is no greater than necessary to further that interest. When weighing the possible likelihood of eliminating school violence, creating an environment conducive for learning, structuring a level playing field, reducing competition, and enhancing school pride and self-esteem versus stymieing the freedom of children to select their school wardrobe, it can be argued that the sides of the scales are not even close to being balanced.
Context Affecting First Amendment Rights
The Supreme Court in Texas v. Johnson (1989) established that the context in which symbolic speech occurs would be used in determining whether a content-neutral government regulation violates the First Amendment. In Johnson, while the 1984 Republican National Convention was taking place in Dallas, Texas, a group of people staged a political demonstration in Dallas to protest the policies of the President of the United States. During the course of that demonstration, one of the protesters (a) accepted an American flag handed to him by a fellow protester, who had taken the flag from a pole outside one of the targeted buildings, (b) doused the flag with kerosene, and (c) set the flag on fire. While the flag burned, the protesters chanted, “America, the red, white, and blue, we spit on you.” The defendant protester appealed his conviction on the ground, among others, that the application of the state statute violated his right to freedom of speech under the Federal Constitution’s First Amendment.
As part of the assessment of the conduct claimed to be symbolic, the Court examined the context in which this conduct took place. The Court found that the political climate and current national events did in fact set the stage for the defendant to convey a particular message. While the message may have been interpreted differently by various groups of people, this did not place the conduct outside the scope of protected speech.
LIMITATIONS ON FIRST AMENDMENTS RIGHTS OF MINORS
First Amendment rights apply to all United States citizens. However, the government may limit these rights depending on the class of citizens involved. For example, the government has broad discretion in limiting the rights of children than adults (Barbarosh, 1995). In Ginsberg v. New York (1968) the Supreme Court recognized that the state has power to control the conduct of children that reaches beyond its scope of authority over adults. School districts are given considerable latitude to ensure an environment that is safe and conducive to learning (Barbarosh, 1995).
The First Amendment limits the government’s ability to regulate speech less stringently when public school students’ First Amendment rights are involved. Although students are “persons” under the Constitution and retain some constitutional rights to freedom of speech and expression while in public schools, the Supreme Court has held that these rights are limited (Tinker v. Des Moines Indep. Seh. Dist., 1969). Because students’ First Amendment rights are not coextensive with those of adults, courts do not apply traditional First Amendment jurisprudence when examining regulations affecting speech in the public schools (Tinker v. Des Moines Indep. Sch. Dist., 1969). Instead, courts examine the necessity of the regulation for maintaining the classroom environment.
The Supreme Court has endorsed an inculcative theory of public school education-that is, one in which public schools impart school-supported knowledge and values (Bethel Sch. Dist. v. Fraser, 1986; Levin, 1986). Under this theory, school authorities may proscribe student speech that appears inconsistent with its “basic educational mission” (Hazelwood Sch. Dist. v. Kuhlmeier, 1988). As a result, schools can censor speech that could not be censored outside the school.
The Court has not given school districts unlimited discretion in determining which speech is permissible. To that end, public school administrators may not proscribe speech merely because they disagree with the message of the speech (Tinker v. Des Moines Indep. Sch. Dist., 1969). For example, in Tinker v. Des Moines Independent School District, the Court found that the suspension of several students for wearing black armbands to protest the Vietnam War violated the First Amendment. In examining the suspension, the Court first determined that personal intercommunication is an integral part of the educational process. Hence, First Amendment rights apply in all situations in which students seek to express themselves freely on the school campus, including in the cafeteria, and hallways, or during extracurricular activities (Tinker v. Des Moines Indep. Sch. Dist., 1969).
Dress codes have encountered more First and Fourteenth Amendment problems with courts than uniform policies. Courts have struck down hair regulations as violating due process rights, and one survey of federal court holdings on hair and dress codes found that the First, Fourth, Seventh, and Eighth Circuits are likely to decide against school administrators in hair and appearance policy conflicts, while the Fifth, Sixth, Ninth, Tenth, and Eleventh Circuits tend to side with school officials (Bartlett, 1986; Breen v. Kahl, 1969). When dress codes or uniform policies conflict with a First Amendment claim of free exercise of religion, under the U.S. Supreme Court’s decision in Sherbert v. Verner (1963), courts should apply strict scrutiny. Thus, dress codes or uniform policies will need to allow for such exceptions. If school boards draft rules regarding body piercing, it may need to find legitimate health and safety concerns to withstand speech and Fourteenth Amendment protections (Haase, 2000). Determining what is proper dress and physical appearance is so problematic for school officials that they are legally safer and generally better off opting for school uniforms rather than dress codes (Killen, 2000).
Opponents of school uniform policies contend that a public school student’s First Amendment right to free speech outweighs the interest of the State to eliminate much of the competitiveness and expense associated with some clothes, to increase the self-respect that is associated with school uniforms, to reduce discipline problems, and to lessen violent behavior. At the same time, a former U.S. President, a former U.S. Attorney General, the National Education Association, the National Association of secondary School Principals, and a litany of school administrators, teachers, parents, and students endorse school uniforms. These proponents view uniforms as having positive impacts. Many proponents also indicate that states have a compelling interest in reducing youth violence associated with clothes and accessories. The law of the land strengthens proponents’ arguments. Courts maintain that content-neutral regulations that satisfy the four-pronged O’Brien Test are constitutional. In addition, the United States Supreme Court holds that states have the power to control the conduct of students. Therefore, many states insist that the implementation of the school uniform policies and the need for student safety outweighs public school students’ rights to select school dress.
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HAROLD MITCHELL is a Staff Attorney for the Sixth Circuit, Montgomery County, Maryland Circuit Court; firstname.lastname@example.org. His interests include education law, civil rights, and alternative dispute resolution.
JOHN C. KNECHTLE is an Associate Professor and Director of International Programs at Florida Coastal School of Law; JKnechtle@FCSL.edu. His interests include Constitutional law, international law, and comparative law.
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