Dress Codes and Uniforms in Public Schools

Abstract

This article discusses dress codes and school uniforms in K–12 public schools in the United States. While virtually every public and private school in the world has either an informal or formal dress code stipulating what students can and cannot wear to school, a required school uniform is not universal. However, in many parts of the world, from Australia to Malaysia and New Zealand to Great Britain, school uniforms are a part of life for public and private school students. In the United States, school uniforms were once the exclusive domain of private and religious schools, but in the 1990s, they began being hailed by some as a solution to issues surrounding drugs, violence, and academic shortcomings afflicting many public schools, particularly in urban areas. Many of the most significant constitutional challenges to public school uniforms have been rejected by the courts, and many parents and administrators credit them with improvements in school safety and academic performance. Critics allege that dress codes and school uniforms violate First Amendment guarantees of freedom of speech and freedom of religion, and they maintain that the results credited to dress codes and school uniforms can be better explained in other ways.

Overview

The practice of requiring students to wear a uniform dates back at least to the sixteenth century in England, where students at the University of Cambridge were required to wear them as a way to halt the spread of new fashions in the hallowed halls of learning.

Historic Relevance. Historically, claims Dussel (2005), school uniforms in the United States in the nineteenth and twentieth centuries were used to keep control over the bodies of racial minorities. The point was to ensure that ethnic and racial minorities were uniform with respect to accepted cultural mores:

From early onwards, such [school uniform] policies were tied to the disciplining of 'unruly', 'savage', 'untamed' bodies, that is, the bodies of those who were not able to perform self-regulation or self-government: women, Black Americans, American Indians, poor classes, immigrants, toddlers or infants. In the nineteenth- and early twentieth-century United States, American Indians and Black Americans were the targets of close surveillance in terms of what to wear and when to wear it. In particular, the introduction of uniforms in Federal Indian Boarding schools meant that tribal attire and moccasins were forbidden, and strict measures were enforced to ensure that children wore 'civilized', Western clothes, including underwear.

Over time, school uniforms became associated with the children of power and privilege. They became a symbol of the opportunities that, at least according to some Marxist-inspired critics, were not available to those of the American middle and lower classes.

Whatever the truth of such analyses, it is beyond dispute that dress codes in general, and school uniforms in particular, became a prominent topic within the larger national discussion on education reform that took place in the 1980s and 1990s. Between the decades-long distraction of the Cold War and the growing upheaval caused by international terrorism, the 1990s was a time when American political and educational leaders turned inward and began to take stock of the public education system. What they saw—low academic standards, rising violence, and disenchanted teachers—was less than satisfactory. In 1983, the National Commission on Excellence in Education proclaimed in the report, "A Nation at Risk" that "the educational foundations of our society are presently being eroded by a rising tide of mediocrity" ("A Nation at Risk," 1983).

On the other hand, private and religious schools in America were seen as continuing to provide quality education and seemed largely immune to the systemic problems afflicting public schools. One of the most visible symbols of the private school, at least to many Americans and their elected officials, was the school uniform. While few considered them to be a panacea, parents, teachers, politicians, and school administrators began to see school uniforms as perhaps part of the answer to the problems afflicting America's public schools. The first known public elementary school in the United States to adopt a school uniform policy was Cherry Hill Elementary School in inner-city Baltimore in 1987.

The Long Beach Experiment. In 1994, the public school system in Long Beach, California, Unified School District was the first school district in the nation to adopt school uniforms, first for the 60,000 students in its 60 elementary schools and 15 middle schools, and then for high schools as well. By the end of 1995, the school crime rate fell by 36 percent. In 1999, five years after the school uniform policy was implemented, its correlation with school-based crime was evident:

The quantitative outcomes of the policy have been remarkable. Crime report summaries for the five-year post-uniform policy period reflect that school crime overall had dropped approximately 86 percent, even though K–8 student enrollment increased 14 percent. The five categories of school crime where comparisons can be made between 1993 levels and 1999 levels are: (a) sex offenses down 93 percent (from 57 to 4 offenses); (b) robbery/extortion down 85 percent (from 34 to 5 cases); (c) selling or using chemical substances down 48 percent (from 71 to 37 cases); (d) weapons or look-a-likes down 75 percent (from 145 to 36 cases); and (e) dangerous devices down 96 percent (from 46 to 2 cases) (LBUSD, 1999; Lopez, 2003).

The apparent success of the Long Beach experiment attracted the notice of the administration of US president Bill Clinton. Attorney General Janet Reno said in December 1995 that President Clinton believed that if uniforms can help fight school violence, they should be supported. According to Brunsma, it was Clinton's January 1996 State of the Union Address that initiated a resurgence of interest in public school uniforms. Early in his speech, Clinton said, "I challenge all our schools to teach character education, to teach good values and good citizenship. And if it means that teenagers will stop killing each other over designer jackets, then our public schools should be able to require their students to wear school uniforms" (Clinton, 1996).

Clinton's speech touched on what was perceived to be the strongest argument for instituting a school uniform policy: the safety of teachers and students. In adopting a standard uniform, students would not be able to use clothes as a sign of power and privilege.

Reasons to Adopt School Uniform. Adopting school uniforms also eliminated gang colors. Gangs were known to use middle schools as recruitment centers, and members of rival gangs would proclaim their allegiance to the gang by wearing the gang's particular colors. According to Holding, one school that revised its dress code to prohibit gang colors, Redwood Middle School in Napa Valley, California, saw palpable results. The school principal believed the uniforms were the direct catalyst for improved safety on campus.

Dress codes and school uniforms have found some of their most vocal advocates among minority groups, especially African Americans, who are most directly and adversely impacted by school violence and declining educational opportunities. According to Dussel, many Black and Hispanic leaders saw school uniforms as a way to move, albeit symbolically, beyond a politics of failure and victimization toward a new day in which they reclaimed their schools and embraced their promise of a bright tomorrow:

School uniforms are being defended by minority leaders in the Black and Latino communities as a way to construct collective identities and generate a new consensus on the need for better schooling…. Using other scholars' views of minority leaders' strategies, they could be read as part of a democratic movement to shape schooling as more respondent and sensitive to demands for recognition and social mobility.

At the end of the 1980s, fewer than 1 percent of elementary schools had uniforms. By the 1999–2000 school year, the number rose to 15 percent. By 2008, major cities such as Atlanta, Boston, Chicago, Dallas/Fort Worth, Detroit, Miami, New York, Houston, New Orleans, Philadelphia, and Washington, DC, had a school uniform policy in the majority of their public schools. According to a 2022 National Center for Education Statistics (NCES) report, the fraction of all American public schools requiring school uniforms rose from 12 percent in 1999–2000 to 18.8 percent in 2019–20.

Political Implications. Even in those schools and school districts that did not adopt school uniforms, political rumbling about a "rising tide of mediocrity" of public schools meant that existing dress codes were closely scrutinized to ensure that students were in a safe environment that was most conducive to learning. Within public school districts, 40 percent had dress codes in place by 1994. Milford High School in Milford, Massachusetts, is one of many schools that reworked its dress code. The school's principal at the time, John Brucato, outlined the school's clothing policy in 2005, which is indicative of the philosophy behind many dress codes in the nation:

We ask our students to dress and groom themselves as individuals with a sense of responsibility and self-respect. So, it's not a matter of what you must wear; it's more of a matter of what we don't feel is appropriate. Specifically, if it becomes disruptive, offensive, threatening, or provocative to others, is vulgar, displays tobacco or alcohol advertising, profanity, racial slurs, has disruptive images of gang-related symbols.

By 2013, the Milford High School dress code had been adjusted to reflect a focus on the expectation of additional schooling or a future career for students after graduation from high school. The message, while more succinct, was much the same as it was eight years previously:

“The Dress Code of Milford High School is designed to help students recognize choices regarding attire that would be appropriate in their future workplace as well as in an educational setting. Students are expected to dress, groom, and attire themselves in a manner that is not potentially dangerous, does not distract others or disrupt education, and does not convey a message contrary to District policy” (Milford High School, 2013).

Like school uniforms, contemporary school dress codes are driven in part by concern over a perceived rising tide of student-on-student violence in public schools, epitomized by such well-publicized public school shootings such as that perpetrated at Columbine High School in Colorado in 1999. At the turn of the twenty-first century, many public schools, with the support of parents, decided to err on the side of caution when it came to student safety. To do this, they often had to fly in the face of popular fads:

Educators' attention has shifted from bra straps and bare midriffs to safety and security. Hoodie pouches and cargo pants pockets have proven handy hiding spots for school contraband—from the dangerous (weapons) to the distracting (cell phones and iPods)—so administrators are prohibiting them.

Some education officials argue that dress codes are a losing battle because they invariably ban some constitutionally protected forms of student expression.In addition, many argued that dress codes could be sexist. Better, officials say, to opt for a proper school uniform. "You'd be amazed at the amount of time administrators have been spending on what kids are wearing to school," said Susan Galletti of the National Association of Secondary School Principals. "With uniforms, all that is eliminated, and they can spend more time on teaching and learning."

Applications: How to Implement a School Uniform or Dress Code Policy. No decision about school uniform or dress codes is ever made in a cultural, historical, or political vacuum. Speaking particularly about school uniforms, Howard Hurwitz, the former principal of the Long Island City High School, noted that it is important not to undersell or oversell them. He believed any public school that seeks to follow the example of parochial schools where uniforms are a tradition should seek prior involvement of parents. Assurance of maximum cooperation must be obtained before announcing a school uniform policy, and "uniforms would be a step in the direction of restoring school discipline, but they are not a panacea" (Hurwitz, 1997).

Guidelines. With support from the Clinton Administration, the US Department of Education published guidelines in 1996 for any public school wishing to implement a school uniform policy, and some of the advice applies equally to public schools wishing to update their existing dress code:

• "Get parents involved from the beginning.
• "Protect students' religious expression.
• "Protect students' other rights of expression.
• "Determine whether to have a voluntary or mandatory school-uniform policy.
• "When a mandatory policy is adopted, determine whether to have an opt-out provision.
• "Do not require students to wear a message.
• "Assist families that need financial help.
• "Treat school uniforms as part of an overall safety program (U.S. Department of Education, 1996).

Generally speaking, the more input school officials can receive from parents and the wider community, the better. A transparent process is often the best way to avoid future problems.

Viewpoints

Do School Uniforms Work?. Much has been written regarding the benefits and demerits of school uniforms and dress codes. Firmin, Smith, and Perry, summarize the work of many researchers:

Although there have been surprisingly few methodical research studies assessing the outcomes of uniform policies, some data suggests lowered violence, gang influence, and improved attendance and academic performance in students. However, critics suggest that the successes of the independent variable in the studies (uniform policies) are confounded. That is, such schools show improvement due to variables such as increased teacher enforcement and involvement with students as well as parental involvement with the school process and system.

Advocates and critics alike agree that creating a sense of order, cohesion, and a positive school climate are essential goals for successful education. However, the debate rages as to whether or not a school uniform policy produces those ends, and if the policy does, then is it the most productive and least restrictive means of doing so? Brunsma argues persuasively that there is no clear answer to these complex issues.

A decade of research seems to indicate what even supporters of school uniforms readily acknowledge—that school uniforms are not a panacea, but they can be one ingredient in a district's recipe for improved school safety and academics.

Free Speech versus School Safety. By implementing a school uniform policy or revisiting their dress codes, public school officials inevitably walk a Constitutional tightrope in balancing student First Amendment free speech and expression protections against the "compelling" government interest to create an environment for students and teachers that is safe for learning.

During the Vietnam War era, the US Supreme Court led by Chief Justice Earl Warren took a liberal view of student rights to protest against the war; the justices were less likely than those on later courts to identify a compelling government interest in curtailing student expression. The seminal case involving student self-expression during this time was Tinker v. Des Moines School District (1969), where the court ruled that a student had the right to wear a black armband in school as a legitimate form of political protest. The decision, and the ambiguous court rulings that followed in the 1970s, had a chilling effect on the implementation of stricter school dress codes.

With changes in the makeup of the Supreme Court in the 1980s, however, the justices were more willing to construe the compelling interests of school officials in broader terms. This meant that dress codes in the 1980s and 1990s were more likely to pass Constitutional muster. In Bethel Schools v. Fraser (1986), the newly constituted Court, which included President Ronald Reagan’s first nominee, limited the scope of Tinker to exclude protections on vulgar student speech. In 2001, the US 5th Circuit Court of Appeals ruled unanimously in Canady v. Bossier Parish School Board that the school board in Louisiana did not violate the First Amendment rights of students when it implemented a parish-wide dress code. "This purpose is in no way related to the suppression of student speech," the three-judge panel wrote. "Although students are restricted from wearing clothing of their choice at school, students remain free to wear what they want after school hours" (eSchool News, 2001).

Legal Challenges. School uniforms and dress codes continue to face legal challenges, however. For example, in July 2007 Napa County Superior Court Judge Raymond Guadagni ruled that the nine-year-old dress code policy of Redwood Middle School was unconstitutional because, as written, it unduly restricted the free speech rights of the students and was interpreted in a way that did not serve obvious government interests. In his injunction against the dress code policy, Guadagni explained why he felt the dress code was too strict:

Under this attire policy, the student plaintiffs have been disciplined for wearing, inter alia, blue jeans, socks with the image of Winnie-the-Pooh's Tigger character, an American Cancer Society pink ribbon for breast cancer awareness, a Vintage High School sweatshirt, a backpack with the brand name "Jansport" written in red, a heart sticker on Valentine's Day, a T-shirt with the words "D.A.R.E. to resist drugs and violence," and a t-shirt reading "Jesus Freak."

Guadagni threw out the district's dress code, but he did not rule on the question of whether dress codes are inherently unconstitutional.

Courts have also ruled that a student has the right to wear a 'Straight Pride' shirt in a Minnesota high school. In 2005, in Maryland, a student was prohibited from attending his high school graduation because he wore a bolo tie, a symbol of his American Indian heritage, but later received an apology from the school. In 2006, a male Missouri student received an apology for not being permitted to wear a kilt to a school dance.

In 2010, two middle school students in Pennsylvania were suspended for wearing breast cancer awareness bracelets with wording that was interpreted by the school as lewd. A federal appeals court ruled in 2013 that the school could not enforce the ban on the bracelets because the wording, in its support for national breast-cancer awareness, was protected as free speech. Similarly, the Ninth Circuit Court of Appeals struck down the mandatory uniform policy of Roy Gomm Elementary School of Washoe County, Nevada, in February 2014 on the basis that its printed motto “compels speech.”

Court rulings have also generally held that dress codes cannot enforce sex or gender stereotypes. For example, in 2019 a federal judge ruled in favor of girls in North Carolina who petitioned against a policy at their public charter school prohibiting them from wearing pants.

Religious Issues. An important dimension of the debate over public school dress codes and uniforms are the limitations put on outward expressions of religious faith by students. As noted above, the US Department of Education recognizes the well-established legal principle that public schools must make reasonable accommodation of students' religious beliefs.

Some of the most well-publicized cases of religious expression have involved female students wearing headscarves. After legal action was brought by a female Muslim student, an Oklahoma public school district allowed her to wear a headscarf. A female Muslim student attending a Regina Catholic High School in Euclid, Ohio, was banned from school because she refused to remove her headscarf, but was then readmitted under orders from officials in the diocese. In 2011, a sixth grader from Nebraska was told she could not wear her rosary to school because rosaries were a symbol in that area of gang affiliation.

In 1995, US Secretary of Education Richard W. Riley expressed the essential relationship between dress codes and constitutional protection of religious liberty:

Students generally have no Federal right to be exempted from religiously-neutral and generally applicable school dress rules based on their religious beliefs or practices; however, schools may not single out religious attire in general, or attire of a particular religion, for prohibition or regulation. Students may display religious messages on items of clothing to the same extent that they are permitted to display other comparable messages. Religious messages may not be singled out for suppression, but rather are subject to the same rules as generally apply to comparable messages (Riley, 1995).

Given the seriousness with which they view any infringement upon students' religious liberty, courts have also shown a willingness to throw out dress codes rather than limit a student's right to religious expression, even if the codes have the greater goal of promoting school safety. Citing decades of court decisions, the Anti-Defamation League summarizes the case law:

A ban on gang-related attire cannot restrict the wearing of religious symbols and will not be upheld where there is no evidence of disruption that justifies infringement on students' religiously motivated symbolic speech. In general, gang-related prohibitions on dress have not fared well in the Courts. Indeed, they have been held to be void for vagueness in a number of circumstances.

As schools consider changing their dress codes or implementing a school uniform policy, they must make reasonable accommodation to students' religious beliefs—and be prepared to prove that any limits placed on religious expression are entirely incidental.

Terms & Concepts

Dress codes: Primarily written statements of what a school views as acceptable and unacceptable clothing and accessories to wear when attending school.

First Amendment: The first amendment to the US Constitution, stipulating several fundamental freedoms enjoyed by Americans, including students.

Freedom of Religion: A freedom enjoyed by Americans in light of a clause in the First Amendment stating that "Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof."

Freedom of Speech: A freedom enjoyed by Americans in light of a clause in the First Amendment stating that "Congress shall make no law … abridging the freedom of speech."

Private Schools: K–12 schools that are privately funded.

Public Schools: K–12 schools that are publicly funded.

School Safety: The objective reality and subjective perception that students and faculty are secure in their person and possessions.

School Uniforms: A certain type of clothing, typically of certain colors, that must be worn by all students.

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