[1] The plaintiffs claimed that an employer's requirement to take maternity leave from public schools violated the Due Process Clause of the Fourteenth Amendment.

[1] In the Court's opinion, Justice Stewart went on to explain: This Court has long recognized that freedom of personal choice in matters of marriage and family life is one of the liberties protected by the Due Process Clause ... By acting to penalize the pregnant teacher for deciding to bear a child, overly restrictive maternity leave regulations can constitute a heavy burden on the exercise of these protected freedoms.

This decision also plays a critical role in the professionalization of teaching by protecting all teachers from arbitrary, political regulations which serve no pedagogical function.

This bias was shared by the male administrators and politicians, who generally ran the schools, and thus married women were discouraged from, and overlooked for, teaching positions.

[2] The compulsory maternity leave rules were grounded in the belief that women were incapable of making their own decisions about work, health care, and their professional competency.