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Three teachers sued two school districts over their maternity leave policies each of which required teachers to take an unpaid leave of absence four to five months previous to their expected date of delivery. The schools maintained that their policies were reasonable because they enabled the schools ample time to find a replacement teacher. This, according to the schools, avoids an unnecessary interruption in class activities and removes physically unfit teachers out of the school. The schools also justified their maternity leave policies on the basis they protected a pregnant teacher and her unborn child, physically and emotionally. The U.S. Supreme Court held that the school policies were unconstitutional under the Due Process Clause of the Fourteenth Amendment.

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