dress code in the 60s and 70s

dress code in the 60s and 70s

Teaching the JAH: September 2004 (Vol. 91, no. 2) Home | About | Contact Us | View All Installments
Flaunting the Freak Flag, by Gael Graham
Sections
Introduction
Article
Teaching the Article
Exercise 1
Exercise 2
Exercise 3
Exercise 4
Primary Sources
Further Reading
Links
Teaching the Article
Exercise 4
Public Opinion
Although the editors of both of the main newspapers in El Paso–the El Paso Times and
the El Paso Herald-Post–belittled the significance of the battle over hair length in the
public high schools, both papers placed the story of Chesley Karr’s challenge to school
ofcials on their front pages and followed his story until it dead-ended with the refusal of
the U.S. Supreme Court to hear Karr’s appeal. Both published multiple editorials about the
case and the subsequent student uprising. Similarly, some citizens of El Paso found the
matter significant enough to write letters about it to the newspaper editors. Four such letters are reproduced here. Two of
the authors find the contest between students and school ofcials gravely important, although they disagree about which
party is right. The other two authors difer over how the case should come out but (in contrast to the first two authors)
agree that the issue is trivial. A fifth letter to advice columnist Ann Landers comments on one defense of long hair; it is
not specifically related to the case in El Paso.
Why do Michael Smith and Clark J. Matthews believe the length of high school boys’ hair is important? What other issues
do they draw in to make their points? What values seem to undergird their opinions? In contrast, what does “I Like It
Short” think about the hair debate? What does Ann Landers’s reply suggest about her opinion on long hair?
Back in El Paso, why do Edna S. Kelly and Mrs. Harry E. Jordan dismiss the controversy as insignificant? What values
permeate their views? Which letter writers wrestle most with the implications of long hair, and which seem to have some
agenda other than hair? Why do they use Karr’s case to pursue the other agenda? As a whole, what can these letters tell us
about the 1960s?
Although the El Paso letters were chosen (out of a large stack of letters) because they cover the range of opinion–two
pro-student, two anti-student; two seeing great signficance, two seeing much ado about nothing–the two letters that
emphasize the triviality of long hair were written by women, and the two letters that emphasize its importance were
written by men. Do you think this is a mere coincidence? What role might gender have played in forming these authors’
opinions? Do you think “I Like It Short” was a man or woman? Why? In what other documents in the other exercises do
you see ideas about gender and gender roles?
The last document in this section is an Associated Press report on Justice Hugo Black’s dismissal of Chesley Karr’s
petition to have the haircut rule suspended while his case worked its way through the courts. Why does Black think Karr’s
case is not worth hearing? With which of the letter writers do you think Black would most agree? Why? Is the author of the
news story a neutral reporter? How do you know?
Documents
A. Letter of Michael Smith to editor, El Paso Herald-Post, Feb. 1, 1971.
B. Letter of Clark J. Matthews to editor, El Paso Times, Feb. 8, 1971.
C. Letter of Mrs. Harry E. Jordan to editor, El Paso Herald-Post, Feb. 5, 1971.
D. Letter of Edna S. Kelly to editor, El Paso Herald-Post, Feb. 10, 1971.
E. Letter from “I Like It Short” to Ann Landers, San Francisco Examiner, June 23, 1971.
F. “Supreme Court Refuses to Hear Long Hair Case,” El Paso Times, Feb. 12, 1971.
Gael Graham, “Flaunting the Freak Flag: Karr v. Schmidt and the Great Hair Debate in American High Schools, 1965-
1975,” Journal of American History, 91 (Sept. 2004), 522-43.
Go to: Article | Teaching the Article | Primary Sources | Further Reading | Links

522 The Journal of American History September 2004
Flaunting the Freak Flag:
Karr v. Schmidt and the Great Hair
Debate in American High Schools,
1965–1975
Gael Graham
For suggestions on how to use this article in the U.S. history classroom, see our
“Teaching the JAH” Web project at .
In the fall of 1970, sixteen-year-old Chesley Karr returned to Coronado High School
in El Paso, Texas, after a summer spent harvesting wheat in the Midwest. During his
working vacation, he had let his hair grow out over his ears and collar. Later he
asserted that his long hair, which he referred to as a “freak flag,” was both “a cultural
statement and a practical matter.” Culturally, he believed his hair identified him as a
supporter of the “peace or hippie movement”; practically, haircuts had been a low
priority on the wheat farm. To his surprise, the high school gym coach refused to
admit him to class; the issue then ascended through the principal’s office to the
school board, which told Karr he could not return to school without a haircut.
Rather than acquiesce, Chesley Karr took his school to court.1
Battles over masculine hairstyles were nothing new in this period. Once the Beatles
and their imitators popularized longer locks in the early 1960s, fierce struggles
ensued between proponents and opponents of the style. Where opponents of long
hair possessed institutional power—in schools, prisons, the military, many workplaces—they
often wielded that power in favor of their fashion choice, mandating
short hair for males. Numerous high schools adopted dress codes that specified how
boys were to wear their hair. By the mid-1960s, however, long-haired students were
fighting back. Many high school students turned to the courts; an astonishing numGael
Graham is associate professor of history at Western Carolina University.
I would like to thank Dominick Cavallo, Rebecca Klatch, Timothy Miller, David Farber, Van Gosse, Mary
Ann Wynkoop, Gayle Fischer, and the anonymous readers for the Journal of American History for their comments
on earlier drafts. Thanks also to Guillermo Cervantes for research assistance, to members of the history department
colloquium at Western Carolina University for their criticism and suggestions, and to Kenneth W. Graham
for advice on legal research.
Readers may contact Graham at <graham@email.wcu.edu>.
1 Chesley Karr telephone interview by Gael Graham, Nov. 26, 2002, notes (in Gael Graham’s possession).
“Freak flag” is from David Crosby, “Almost Cut My Hair,” performed by Crosby, Stills, Nash, & Young, Déjà Vu
(compact disk; Atlantic 82649; 1970).
The Great Hair Debate in American High Schools, 1965–1975 523
ber, including Chesley Karr, sought justice from federal rather than state courts.
High school boys dominated the federal court cases relating to hair regulations. Over
one hundred hair cases were appealed to the U.S. Circuit Courts of Appeals; nine
appealed all the way to the U.S. Supreme Court. For the historian, these cases open a
window on multiple conversations that reveal the fault lines and fissures in American
society. While the issue of long hair on minor boys may seem trivial today—many
contemporaries, including judges, found it trivial then—the tenacity with which
both proponents and opponents of long hair pursued judgments in their favor forces
us to ask: What was that all about? What can it tell us about the era known as “the
sixties”?
Adopting a social and cultural perspective, this paper examines the legal challenges
to high school rules about the length of male students’ hair considered in the federal
appellate courts. The testimonies of the students and school administrators reveal
what each believed was at stake. Similar testimony about the significance of long hair
comes from court opinions, editorials, and letters from ordinary Americans. Sorting
through the opinions of these four groups—students, school officials, judges, and the
public—sheds light on two separate but related phenomena: the high school student
rights movement and the public debate about masculine long hair. In the end, no
consensus emerged on what long hair meant or why it mattered (or failed to matter).
The battle between students and school officials ended with similar ambiguity:
although neither students nor administrators scored a complete victory in the hair
debate, when the surge of high school student activism ended around 1975, school
officials’ power over students had sharply declined, largely due to judicial decisions.
That change marks an important phase in the history of childhood and suggests that
our understanding of the revolutions of the 1960s and the role of the courts in shaping
them needs to be broadened to include some of the youngest members of society.2
2 Most works that examine the movements of the 1960s include some discussion of the college student revolt
against in loco parentis policies. Few do more than mention high school student activism. See Terry M. Anderson,
The Movement and the Sixties: Protest in America from Greensboro to Wounded Knee (New York, 1995); John Morton
Blum, Years of Discord: American Politics and Society, 1961–1974 (New York, 1991); David Burner, Making
Peace with the Sixties (Princeton, 1996); Stewart Burns, Social Movements of the 1960s: Searching for Democracy
(Boston, 1990); David Chalmers, And the Crooked Places Made Straight: The Struggle for Social Change in the 1960s
(Baltimore, 1991); Dominick Cavallo, A Fiction of the Past: The Sixties in American History (New York, 1999);
David Farber, The Age of Great Dreams: America in the 1960s (New York, 1994); David Farber, ed., The Sixties:
From Memory to History (Chapel Hill, 1994); Todd Gitlin, The Sixties: Years of Hope, Days of Rage (New York,
1993); Kenneth J. Heineman, Campus Wars: The Peace Movement at American State Universities in the Vietnam Era
(New York, 1993); Maurice Isserman and Michael Kazin, America Divided: The Civil War of the 1960s (New York,
2004); Ron Jacobs, The Way the Wind Blew: A History of the Weather Underground (New York, 1997); Landon Y.
Jones, Great Expectations: America and the Baby Boom Generation (New York, 1980); Kim McQuaid, The Anxious
Years: America in the Vietnam-Watergate Era (New York, 1989); Douglas T. Miller, On Our Own: Americans in the
Sixties (Lexington, Mass., 1996); Edward P. Morgan, The Sixties Experience: Hard Lessons about Modern America
(Philadelphia, 1991); Doug Owram, Born at the Right Time: A History of the Baby-Boom Generation (Toronto,
1996); Abe Peck, Uncovering the Sixties: The Life and Times of the Underground Press (New York, 1985); Thomas
Powers, Vietnam, the War at Home: Vietnam and the American People, 1964–1968 (Boston, 1984); Kirkpatrick
Sale, SDS (New York, 1973); Edward K. Spann, Democracy’s Children: The Young Rebels of the 1960s and the Power
of Ideals (Wilmington, Del., 2003); David Steigerwald, The Sixties and the End of Modern America (New York,
1995); and Tom Wells, The War Within: America’s Battle over Vietnam (Berkeley, 1994). Similarly, works that focus
on education in this era generally ignore high school activism. See Gerald Lee Gutek, American Education, 1945–
2000: A History and Commentary (Prospect Heights, 2000); Donald H. Parkerson and Jo Ann Parkerson, Transitions
in American Education: A Social History of Teaching (New York, 2001); Diane Ravitch, The Troubled Crusade:
524 The Journal of American History September 2004
Federal court cases range over the national conversation about long hair, providing
a bird’s-eye view. They allow us to probe the attitudes of school officials and students,
and sometimes those of parents and teachers. Zooming in on a specific case and the
publicity surrounding it enables us to incorporate the voices of observers, not just
those of direct participants. For that reason, this paper interweaves the story of the
haircut cases heard by federal appellate courts with the story of Chesley Karr’s lawsuit
and public reaction to it in his hometown, El Paso, Texas. Both of the main newspapers—the
El Paso Times and the El Paso Herald-Post—covered the highlights of Karr’s
case on their front pages. They also published a handful of editorials and, in total,
more than fifty letters from readers on the issue. The newspapers comments offer
useful counterpoint to the clear, incisive, and well-reasoned court opinions. For the
historian, the combination of local, loosely argued popular commentary on long hair
and coherent, legalistic views provides a broad yet manageable set of sources, a sampling
that opens up the richness of the hair debate.3
The haircut controversy must be seen in a dual context: the social significance of
hair and the high school setting. Anthropologists, historians, and sociologists have
long realized the symbolic significance of hairstyles through time and across cultures,
and some have attempted to explain how hair has functioned in different societies.
While early theorists posited a connection between hair and sexual mores (long flowing
hair corresponding to unrestrained sexuality), others have found the symbolism
of hair more nuanced and specific to the era and society under scrutiny. In American
history, both clothing and hair have occasionally taken on political connotations.
Hair had sparked controversies before the 1960s. Puritan magistrates in colonial
times condemned whites who wore their hair long “after the manner of savages.”
Nineteenth-century boarding schools for Indians forced haircuts on their charges
because the missionaries who ran them regarded the students’ braids as a refusal to
assimilate into white culture. Throughout the twentieth century, African Americans
have uneasily debated “good hair” and “bad hair,” along with the politics and aesthetics
of hair straightening, in the context of racial pride, assimilation, and black nationalism.
While that controversy centered on race, gender anxieties undergirded debates
about white women’s bobbed hair in the 1920s.4
American Education, 1945–1980 (New York, 1983); David B. Tyack and Elisabeth Hansot, Managers of Virtue:
Public School Leadership in America, 1820–1980 (New York, 1982); and Jonathan Zimmerman, Whose America?
Culture Wars in the Public Schools (Cambridge, Mass., 2002). On activism at a single high school in Los Angeles,
see Marc Jason Gilbert, “Lock and Load High: The Vietnam War Comes to a Los Angeles Secondary School,” in
The Vietnam War on Campus: Other Voices, More Distant Drums, ed. Marc Jason Gilbert (Westport, 2001), 174–
93. On high school antiwar sentiment and the First Amendment, see Charles Howlett, “When the Bell Rings:
Public High Schools, the Courts, and Anti–Vietnam War Dissent,” ibid., 194–215. For single chapters on high
school activism and dissent, see Thomas Hine, The Rise and Fall of the American Teenager (New York, 1999); and
Grace Palladino, Teenagers: An American History (New York, 1996). 3 The haircut cases also occurred at a historically fortuitous moment. In the late 1960s and early 1970s, as the
pressure on federal dockets grew, judges sorted cases by how much time they believed each merited. As a result, the
number of appeals affirmed without a written opinion increased dramatically; by 1977 over a third of all appeals
were mutely affirmed. Thus as the number of cases involving high school students increased, it became harder to
understand judicial opinion. Deborah J. Barrow and Thomas G. Walker, A Court Divided: The Fifth Circuit Court
of Appeals and the Politics of Judicial Reform (New Haven, 1988), 149. 4 Anthony Synnott, “Shame and Glory: A Sociology of Hair,” British Journal of Sociology, 38 (Sept. 1987),
381–413; Wendy Cooper, Hair: Sex, Society, and Symbolism (New York, 1971); Diane Simon, Hair: Public, Politi-
The Great Hair Debate in American High Schools, 1965–1975 525
Well before the 1960s, then, Americans used hair as well as clothing to encode
specific social values or identities, often in opposition to mainstream cultural norms.
The appearance of the British rock group the Beatles on the Ed Sullivan Show in February
1964 gave national visibility to hair worn longer than the current fashion and
initiated a slow-burning but ultimately passionate confrontation between proponents
and opponents of long hair. The Beatles first adopted the style to attract attention,
but their hair quickly became entangled with their (generally low-key and humorous)
mocking of middle-class respectability. Through the decade, as increasing numbers of
young men grew their hair out, the provocative, antagonistic connotations of the
style overshadowed mere fashion, and both defenders and attackers attributed a panoply
of meanings to long hair.5
Long hair had not only political and cultural significance but also distinctive racial
meanings. Among African Americans a preference for wearing a “natural” rather than
straightening their hair or imitating white styles emerged from black nationalist ideologies
and the black power movement of the mid- to late 1960s. Malcolm X’s
famous self-criticism of the “conked” (chemically straightened) hair he had worn as a
young man typified blacks’ repudiation of efforts to “whiten” their hairstyles. As the
1960s progressed, naturals—like the long hair on white men—grew longer and
bushier. Native American and Chicano men who grew their hair out sought to
reclaim the heritage of their ancestors, a heritage they believed whites had attempted
to destroy.6
cal, Extremely Personal (New York, 2000). On the Puritan condemnation of long hair, see Dale Gaddy, Rights and
Freedoms of Public School Students: Directions from the 1960s (Topeka, 1971), 25. Zitkala-Sâ, “Growing Up Indian
in a White Man’s World,” in The American Record: Images of the Nation’s Past, ed. William Graebner and Leonard
L. Richards (2 vols., Boston, 2001), II, 67–73; Helen Bradley Foster, New Raiments of Self: African American
Clothing in the Antebellum South (New York, 1997); Shane White and Graham White, Stylin’: African American
Expressive Culture from Its Beginnings to the Zoot Suit (Ithaca, 1998); Noliwe M. Rooks, Hair Raising: Beauty, Culture,
and African American Women (New Brunswick, 1996); Lois W. Banner, American Beauty (New York, 1983);
Ruth P. Rubinstein, Dress Codes: Meanings and Messages in American Culture (Boulder, 2001); Penny Storm, Functions
of Dress: Tool of Culture and the Individual (Englewood Cliffs, 1987); James P. Spradley and David W.
McCurdy, eds., Conformity and Conflict: Readings in Cultural Anthropology (Boston, 1977); Justine M. Cordwell
and Ronald A. Schwarz, The Fabrics of Culture: The Anthropology of Clothing and Adornment (New York, 1979). 5 Ian McDonald, Revolution in the Head: The Beatles’ Records and the Sixties (New York, 1994); Philip Norman,
Shout! The Beatles in Their Generation (New York, 1981). Long hair surfaced as a sign of cultural opposition before
the Beatles. Elvis Presley’s long, greased-up hair formed part of his bad-boy image, but with his three kinds of hair
pomade and eye shadow, Elvis represented the artifice and illusion of the 1950s far more than the “natural” style of
the 1960s. A clearer genealogical line from 1960s longhairs runs back to the beats and to pro–Fidel Castro Americans
(who admired the hairy virility of the Cuban rebel leader). Peter Guralnick, Last Train to Memphis: The Rise of
Elvis Presley (Boston, 1994), 68, 71, 91, 172; Pete Daniel, Lost Revolutions: The South in the 1950s (Chapel Hill,
2000), 135, 151; Van Gosse, Where the Boys Are: Cuba, Cold War America, and the Making of a New Left (London,
1993), 112–13; Van Gosse, “‘We Are All Highly Adventurous’: Fidel Castro and the Romance of the White Guerilla,
1957–1958,” in Cold War Constructions: The Political Culture of United States Imperialism, 1945–1966, ed.
Christian G. Appy (Amherst, 2000), 238–56. 6 Malcolm X with Alex Haley, The Autobiography of Malcolm X (New York, 1965), 54–57. High school students
of color rarely sued their schools over hair regulations; when they did, the issue often involved something
other than hair length. For example, Darius Lovelace, an eighteen-year-old African American student in Pennsylvania,
sued after he was suspended for wearing a mustache, as did three black students from Wheeler County,
Georgia. See Lovelace v. Leechburg Area School District, 310 F. Supp. 579 (1970); and Stevenson v. Wheeler County
Board of Education, 306 F. Supp. 97 (1969). Only one Asian American sued over hair length; he claimed no connection
between his hair and racial pride. Yoo v. Moynihan, 28 Conn. Supp. 375 (1969). The parents of one fifthgrade
Native American child sued, claiming that the short-hair rule “violated their parental rights to raise their
children according to their religious, cultural, and moral values.” Hatch v. Goerke, 502 F.2d 1189 (1974).
526 The Journal of American History September 2004
White high school students who wanted to grow their hair long first did so in imitation
of rock idols. Bob Greene, a high school student in Bexley, a white suburb near
Columbus, Ohio, noted in his 1964 diary that although his father, to his surprise,
had liked the Beatles when they appeared on television, he would not permit Bob to
wear a “Beatle haircut.” Nor would school authorities: Greene’s diary documents
repeated confrontations with his high school principal over his hair. Greene backed
down and cut his hair every time, but in the fall of 1964, Edward T. Kores, a high
school student at Westbrook High School in Westbrook, Connecticut, created a stir
by refusing to comb his bangs off his forehead until after school authorities suspended
him. Two years later, three members of a high school rock band called
Sounds Unlimited in Dallas sued their school in federal court; that became the first
high school haircut case appealed to the federal Circuit Courts of Appeals and to the
U.S. Supreme Court.7
Well before, many public high schools had exerted control over their students’
apparel and general appearance, and in the rare instances when students challenged
that control in court, the courts sided with the schools. Rules governing students’
appearance tightened in the years following World War II because of altered circumstances
in high schools. Due to state laws mandating high school attendance, the erosion
of job opportunities for minors, the general prosperity that relieved many young
people of the obligation to help support their families, and the baby boom, high
school students were no long primarily middle class, and overcrowding plagued
many urban and suburban high schools. Officials intended dress codes not only to
manage the larger numbers of students jostling in the halls but also to diminish classbased
distinctions and to prevent middle-class students from adopting the sartorial
styles of the rough kids from across the tracks—whose clothing may have been less a
matter of style than of necessity. For example, most schools forbade blue jeans and
mandated tucked-in shirts with collars for boys, imposing middle-class (and increasingly
age-linked) values about respectable attire. The juvenile delinquency scare that
peaked in the early 1950s added urgency to the campaign to control students. The
popular media fanned the flames of this panic with reports about “crime sprees”
among middle-class youth, while the U.S. Senate held hearings to investigate the
causes of juvenile delinquency. According to the historians Grace Palladino and
James Burkhart Gilbert, parents who feared juvenile delinquency pressured school
officials to establish dress codes, hoping that conformity in dress could contain student
behavior. One source cites the Buffalo Plan, a late-1950s dress code devised in
Buffalo, New York, as the inspiration for dress codes in other areas.8
7 Bob Greene, Be True to Your School: A Diary of 1964 (New York, 1987), viii, ix, 53, 271, 282–83; New York
Times, Sept. 13, 1965, sec. 1, p. 37. In this first haircut case neither the student plaintiffs nor the school defendants
attributed any symbolic meaning to hair. The students did, however, write a song about their confrontation
with the school that got local airtime. Ferrell v. Dallas Independent School District, 261 F. Supp. 545 (1966), 392
F.2d 697 (1968), 393 U.S. 856 (1968). 8 Jones v. Day, 127 Miss. 136 (1921); Pugsley v. Sellmeyer, 158 Ark. 247 (1923); Palladino, Teenagers, 162;
Arlene S. Skolnick, Embattled Paradise: The American Family in an Age of Uncertainty (New York, 1991); James
Burkhart Gilbert, A Cycle of Outrage: America’s Reaction to the Juvenile Delinquent in the 1950s (New York, 1986),
16; Board of Education, Buffalo, New York, School-Community Coordination, “Recommendations of the Inter–
High School Student Council for Appropriate Dress of Students in High School,” in American Record, ed. Graeb-
The Great Hair Debate in American High Schools, 1965–1975 527
Whether officials responded to parental pressure, mimicked other schools, or
acted on their own perceptions of student behavior, dress codes proliferated. They
often included regulations on masculine hairstyles, ranging from vague bans on
“extreme hair styles” to specific instructions about how boys’ hair should be cut.
Dress codes commonly stipulated that hair could not cover eyebrows, ears, or collars.
Many added regulations about the length and width of sideburns, as they became
fashionable, and banned beards, mustaches, and goatees.9
But such regulations increasingly ran against the tides of the times, not only the
popularity of longer hairstyles among the young, but also the rise of activism and dissent
among high school students. Although historians and the popular memory of
the 1960s have only sporadically recognized it, public schools were battlegrounds for
hotly contested political and cultural issues. Conflicts over school desegregation, busing,
sex education, school prayer, and decentralization of school systems obviously
involved the schools, although few have noted what roles students played or how
those battles shaped their school experiences. Moreover, histories of the civil rights
movement, the black and Chicano power movements, the Native American movement,
the women’s movement, gay liberation, the counterculture, the sexual revolution,
and the antiwar movement generally focus on adult actors, ignoring the fact that
high schools could not be insulated from them; indeed, high school activists can be
found in all those movements. Since students did not always restrict their activism to
after-school hours and since some school officials sought to control students’ out-ofschool
activities, high schools were pulled into the cultural and political maelstrom.10
The rights and identity revolutions that were shattering the social status quo could
not be confined to adults. High school students found that for them those revolutions
necessarily went hand in hand, for in order to proclaim their identity as members
of the youth culture or counterculture, they first had to establish their right to
do so. Thus activist high school students too fought to be included in the now-widening
circle of citizenship. In a landmark 1969 case, Tinker v. Des Moines Independent
ner and Richards, II, 320–21. I have seen no other references to the Buffalo Plan, so its influence is unclear. Some
schools did not adopt dress codes immediately. Shawnee High School in Wolf Lake, Illinois, for example, did not
have a dress code until 1972. See Copeland v. Hawkins, 352 F. Supp. 1022 (1973). 9
General hair rules appear in Laine v. Dittman, 259 N.E.2d 824 (1970). Detailed hair regulations are cited in
Arnold v. Carpenter, 459 F.2d 939 (1972). 10 Some works on either the Chicano or the civil rights movements make it clear that high school students
often served as the shock troops of the movements. Even here, however, historians portray high school students
more as ad-libbing walk-ons than as primary actors. John Dittmer, Local People: The Struggle for Civil Rights in
Mississippi (Urbana, 1994), 126; Adam Fairclough, Race and Democracy: The Civil Rights Struggle in Louisiana,
1915–1972 (Athens, Ga., 1995), 156, 214; Charles M. Payne, I’ve Got the Light of Freedom: The Organizing Tradition
and the Mississippi Freedom Struggle (Berkeley, 1995), 225, 271; Edward J. Escobar, “The Dialectics of Repression:
The Los Angeles Police Department and the Chicano Movement, 1968–1971,” Journal of American History,
79 (March 1993), 1483–1514; Carlos Muñoz, Youth, Identity, Power: The Chicano Movement (New York, 1989),
99–103; David F. Gomez, Somos Chicanos: Strangers in Our Own Land (Boston, 1973), 100–110; John Staples
Shockley, Chicano Revolt in a Texas Town (Notre Dame, 1974); Ignacio M. García, Chicanismo: The Forging of a
Militant Ethos among Mexican Americans (Tucson, 1997); Ernesto B. Vigil, The Crusade for Justice: Chicano Militancy
and the Government’s War on Dissent (Madison, 1999). Jonathan Zimmerman pays some heed to the initiatives
of African American students in changing racist history textbooks and adding black studies to the high school
curriculum. But he also asserts that most controversies involving schools “stormed over the schoolhouse rather
than inside it.” That was certainly not true in the late 1960s and early 1970s. Zimmerman, Whose America?, 108–
28, 222.
528 The Journal of American History September 2004
Community School District, the U.S. Supreme Court ambiguously affirmed the status
of high school students as citizens. The case became the touchstone for federal and
appellate court judges who heard haircut cases in the late 1960s and early 1970s.
Since the ambiguity of the Court’s ruling allowed lower court judges to rule either for
or against regulating long hair on high school boys and justified limited citizenship
for minors, the case deserves a closer look.
In 1965 school officials in Des Moines, Iowa, suspended two high school boys and
one junior high school girl for wearing black armbands to school in violation of a
recently adopted rule against such demonstrations. In fact, school officials had promulgated
the rule only after learning that some students planned to wear the armbands
as a gesture of mourning for the dead in Vietnam. When the case came before
the Supreme Court, the ruling concluded that armbands were “akin to free speech”
and thus protected by the First Amendment. In a sweeping statement that seemed to
draw minors into full citizenship with adults, Justice Abe Fortas, who penned the
majority opinion, wrote: “First Amendment rights, applied in light of the special
characteristics of the school environment, are available to teachers and students. It
can hardly be argued that either students or teachers shed their constitutional rights
at the schoolhouse gate. This has been the unmistakable holding of this Court for
almost fifty years.” Fortas added: “In our system, state-operated schools may not be
enclaves of totalitarianism.”11
But Justice Fortas undercut the protection afforded minors under the First
Amendment in matters of personal appearance by adding, “The problem posed by
the present case does not relate to the regulation of the length of skirts or the type of
clothing, to hair style, or deportment.” In a concurring opinion, Justice Potter Stewart
emphasized that, although he agreed that schoolchildren were “persons” under the
Constitution, he could not support the notion that “the rights of children are coextensive
with the rights of adults.” Stewart’s opinion left unanswered the question of
which adult rights children possessed; Fortas’s comments about school rules concerning
apparel and hair left open the possibility that children had no right to choose
how to present themselves physically to the world. Hundreds of high school students—often
allied with the American Civil Liberties Union (ACLU)—went to court
to define and broaden the rights children could claim, including the right to wear
their hair as they wished, while school officials tenaciously sought to deny them legal
victories. The courts, caught in the line of fire, sought to balance the “special characteristics
of the school environment” with the rights of individuals constrained to be
in that environment.12
Thus by the time Chesley Karr sued school administrators at Coronado High
School in 1970, adults and children had already joined battle over the rights of
11 John W. Johnson, The Struggle for Student Rights: Tinker v. Des Moines and the 1960s (Lawrence, Kans.,
1997), 3–27; Tinker v. Des Moines Independent School District, 393 U.S. 503 (1969). 12 Tinker v. Des Moines, 393 U.S. at 503. On high school press freedom, see Shanley v. Northeast Independent
School District, 462 F.2d 960 (1972); Quarterman v. Byrd, 453 F.2d 54 (1971); and Scoville v. Board of Education of
Joliet Township High School District, 425 F.2d 10 (1970). Student political expression was handled in Guzick v.
Drebus, 305 F. Supp. 472 (1969). Due process in high school discipline was established in Goss v. Lopez, 419 U.S.
565 (1975).
The Great Hair Debate in American High Schools, 1965–1975 529
minors, and hair was a key issue in the battle. In a pattern repeated in other high
schools, twenty-one other Coronado High School boys initially refused to abide by
the school’s hair regulations but backed down when threatened with suspension.
Karr, on the other hand, held fast. As he has recently noted, he had “the opportunity
and resources to say ‘no.’” His father testified at trial, “Nobody told me how to cut
my hair when I was in school.” The elder Karr, an insurance agent, also told the court
that, although he did not want his son to break rules for the sport of it, he did want
him to stand up for his individual rights. Not only did his parents uphold his right to
wear his hair as he wished, they believed he had little to lose in challenging the school
administration. Even if school officials expelled him, Karr knew he had “the skills
and ability, that [he] could be successful without school being imposed.” Moreover,
his parents knew some ACLU lawyers, who took an interest in the case.13
Karr’s case first went to the school board, but the board upheld the haircut rule. In
a 2002 interview Karr judged that the board “didn’t like young high school kids trying
to buck the system. They saw [opposition to the rules] as part of the protest era of
the late 1960s. . . . It threatened their authority. They didn’t want some punk telling
them how to run their operation.” While school officials undoubtedly feared the
diminution of their power, Karr’s rebellion may have seemed especially provocative
Chesley Karr in 1970, the year in which he
challenged the haircut rules at Coronado
High School in El Paso, Texas. Courtesy
Chesley Karr.
13 El Paso Times, Nov. 11, 1970, p. A5. For the statements by John R. Karr, Chesley’s father, see El Paso HeraldPost,
Nov. 9, 1970, p. A1; and El Paso Times, Nov. 11, 1970, p. A5. In the El Paso school system, 162 of 21,000
high school students violated the dress code, but all of them—save Karr—immediately complied. Ibid., Nov. 13,
1970, p. A10; Karr interview.
530 The Journal of American History September 2004
since they had slightly liberalized the dress code prior to his challenge. In line with
the advice of numerous “experts” in journals of education and school management,
the Board of Trustees of the El Paso Independent School District had created an ad
hoc committee of twenty-four members, including some high school students, to
study dress codes in other school districts in Texas and make recommendations. Clifford
Schmidt, chair of the committee and principal of Coronado High School,
asserted that “student representatives were given ample time to speak on any and all
matters” and that he had voted only once—to break a tie on the question of facial
hair for male students (he voted against it).14
When the school board ruled, Karr, with the backing of his parents and the ACLU,
took the next step and sued in federal court, asserting that the school’s regulations
violated the First, Ninth, and Fourteenth amendments. Courtroom testimony took
four days; Karr and both his parents testified, as did nine other high school students,
two professors from the University of Texas at El Paso (UTEP), the mayor, and a clinical
psychologist, all summoned by the plaintiffs. Witnesses for the school administration
included the football coach from Austin High School, three local high school
students, three teachers, two high school activities directors, three assistant principals,
four high school principals, the superintendent of schools, and the president of
the board of trustees.15
In their testimony, Karr and his witnesses emphasized students’ individual rights,
although they simultaneously argued that the school dress code usurped the rights of
parents to oversee their children’s appearance. They also attempted to refute the scattershot
approach of the defendants, who attacked masculine long hair from half a
dozen different angles.
Ideas about gender formed a major component in the testimony. When Chesley
Karr rebutted the school’s claim that boys’ long hair caused disruption by pointing
out that girls’ long hair apparently bothered no one, the school’s lawyer, Morris
Galatzan, pounced: “You admit that girls are psychologically and physiologically different.”
Karr conceded the point and admitted that it would not be a “good idea” for
boys to pull their hair back in just the ways girls did. Still, he insisted that if safety
required it, boys could clip their hair back out of the way. “You mean if you tied your
long hair with a pretty red ribbon in back you would not cause disruptions?” Galatzan
probed. Again Karr fell back, but he argued that “society would not allow it,”
intimating that the fault lay in society’s reception of masculine long hair, not the hair
itself. Several defendants also emphasized gender roles. Jerry Wilson, the football
coach at Austin High School, testified that his players had voted to get “gentlemen’s
14 Karr interview; El Paso Times, Nov. 11, 1970, p. A5; ibid., Nov. 12, 1970, p. F1; ibid., Nov. 13, 1970, p.
A10. Citing then-current court cases on hair and student rights, many educators urged school administrators to
solicit student input in formulating dress and behavior codes, and to justify such rules by educational necessity
rather than authority. See David Martin, “The Rights and Liberties

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