Davenport v. Randolph County Board of Education
730 F.2d 1395 (1984)
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Rule of Law:
A public high school's grooming policy for student-athletes, such as a "clean-shaven" rule, is per se constitutionally valid and does not violate students' due process rights, as participation in interscholastic athletics is a privilege, not a constitutionally protected interest.
Facts:
- Ronald Watters, the football and basketball coach at Randolph County High School (RCHS), maintained a grooming policy prohibiting team members from having beards or certain types of mustaches and sideburns.
- Jonathan Davenport and Micky Lazar O’Neal were high school students at RCHS.
- In December 1981, Coach Watters suspended Davenport from the basketball team for refusing to shave.
- Coach Watters subsequently barred both Davenport and O'Neal from participating on the 1982 football team due to their refusal to comply with the grooming policy.
- The students' fathers supported their sons' refusal to shave, citing their own past experiences with skin problems caused by shaving.
- The students did not present any medical evidence to the school or court indicating that they themselves were likely to suffer from skin problems.
- The Randolph County School Board, after initially suggesting flexibility, ultimately endorsed Coach Watters' "clean shaven" policy.
Procedural Posture:
- Plaintiffs Jonathan Davenport and Micky Lazar O’Neal filed suit in federal district court against Coach Ronald Watters and the Randolph County School Board under 42 U.S.C. § 1983.
- The plaintiffs sought a declaratory judgment and an injunction to prevent the defendants from enforcing the grooming policy against them.
- The district court found that the policy was adopted for a legitimate objective and was not racially motivated.
- The district court denied the plaintiffs' request for relief.
- The plaintiffs (appellants) appealed the district court's decision to the United States Court of Appeals for the Eleventh Circuit.
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Issue:
Does a public high school's grooming policy, which requires student-athletes to be clean-shaven, violate students' constitutional rights under the Fourteenth Amendment?
Opinions:
Majority - Kravitch, Circuit Judge
No, a public high school's grooming policy for student-athletes does not violate students' constitutional rights. Citing precedent from Karr v. Schmidt, the court held there is a per se rule that high school grooming regulations are constitutionally valid as a reasonable means of furthering the school's interests in teaching hygiene, instilling discipline, and asserting authority. The court dismissed the students' concern about potential skin problems because they presented no medical evidence that they personally would suffer from such issues, leaving open the question of whether such evidence could create a constitutional violation. Furthermore, the court rejected the due process claim related to diminished college scholarship opportunities, affirming prior holdings from Mitchell v. Louisiana High School Athletic Association that participation in interscholastic athletics is a 'mere expectation' or privilege, not a constitutionally protected property interest.
Analysis:
This decision solidifies the significant legal deference granted to school boards in regulating student conduct, particularly within the context of extracurricular activities. It reinforces the precedent that grooming codes in high schools are presumptively constitutional and unlikely to be overturned unless a plaintiff can demonstrate discriminatory intent or arbitrary application. The case draws a sharp distinction between the fundamental right to an education and the privilege of participating in athletics, effectively placing the latter outside the scope of due process protection regarding eligibility rules.
