A.A. ex rel Betenbaugh v. Needville Independent School District

611 F.3d 248 (2010)

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A.A. ex rel Betenbaugh v. Needville Independent School District

United States Court of Appeals for the Fifth Circuit
611 F.3d 248 (2010)

Facts

A.A. (plaintiff) was a kindergarten student in Needville, Texas. The Needville school district (the district) (defendant) had a grooming policy, which provided, in part, that boys’ hair must not cover any part of their ears or reach the top of their shirt collars. A.A., who was Native American, had never cut his hair and wore it either unbraided or in one or two braids. His family, as part of their religion, believed long hair represented a connection to their ancestors and symbolized their Native American cultural identity. A.A.’s parents requested that he be exempt from the grooming policy on religious grounds. The district did not grant A.A. a full exemption; instead, it permitted him to wear his hair either in a single braid tucked into his shirt or in a bun. A.A. did not comply, and he was suspended. A.A.’s parents sued, contending that the district violated the Texas Religious Freedom Restoration Act (TRFRA). The district proffered five justifications for the policy: hygiene, instilling discipline, preventing disruption, avoiding safety hazards, and asserting authority. The district court agreed with A.A.’s parents and issued an injunction against the district. The district appealed.

Rule of Law

Issue

Holding and Reasoning (Higginbotham, J.)

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