Fields v. Palmdale School District (PSD)
447 F.3d 1187 (2006)
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Rule of Law:
The substantive due process right of parents under the Fourteenth Amendment to direct the care, custody, and control of their children does not include a fundamental right to dictate the curriculum or restrict the flow of information in public schools.
Facts:
- Parents of schoolchildren in the Palmdale School District objected to the school's administration of a psychological assessment questionnaire.
- The questionnaire contained several questions that referred to subjects of a sexual nature.
- The parents believed that the survey interfered with their fundamental right to control their children's upbringing by introducing them to sexual matters contrary to their personal and religious values.
- Prior to administering the survey, the school district notified the parents and sought their consent.
- All but one of the parents who later sued signed and returned the consent form, and none objected at that time.
Procedural Posture:
- Parents of schoolchildren (Plaintiffs) sued the Palmdale School District in the U.S. District Court for the Central District of California.
- The district court granted the school district's motion and dismissed the parents' federal substantive due process claim for failure to state a claim upon which relief could be granted.
- The district court also dismissed the parents' state law claims without prejudice.
- The parents (Appellants) appealed the dismissal of their federal claims to the U.S. Court of Appeals for the Ninth Circuit.
- A three-judge panel of the Ninth Circuit affirmed the district court's decision.
- The parents then filed a petition for rehearing en banc with the Ninth Circuit.
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Issue:
Does the Fourteenth Amendment's substantive due process right of parents to direct the upbringing of their children permit them to prohibit a public school from administering a questionnaire containing information and questions of a sexual nature?
Opinions:
Majority - Per curiam
No. The Fourteenth Amendment's substantive due process right of parents to make decisions regarding their children's education does not entitle them to enjoin public schools from providing information the school boards deem educationally appropriate. While the Supreme Court in cases like Meyer v. Nebraska and Pierce v. Society of Sisters established a parent's right to control a child's upbringing, this right is not absolute. Citing precedent from other circuits like Brown v. Hot, Sexy and Safer Productions, Inc., the court held that the Meyer-Pierce right does not extend to restricting the flow of information within public schools. Parents do not possess a fundamental right to direct how a public school teaches their child. The decision of what information to provide is a matter for local school boards, not federal courts, to decide under the Due Process Clause.
Analysis:
This decision significantly clarifies the boundaries of the Meyer-Pierce parental rights doctrine within the context of public education. It establishes that while parents retain the right to choose alternatives to public schooling, they do not possess a constitutional veto over the specific content of a public school's curriculum under the banner of substantive due process. This ruling strengthens the authority of school boards to set educational policy on sensitive subjects, pushing parental challenges out of the federal courts and into the political arena, such as school board elections and legislative advocacy. Consequently, future litigants attempting to challenge public school curricula on these grounds will find it difficult to state a viable substantive due process claim.
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