Main
Dixon v. Alabama has had a monumental role in the modern student conduct process since the day of its inception. The case first originated in the Southern District of Alabama before it made its way up to the Fifth Circuits of Appeals. At first, the District Judge ruled in favor of the board, upholding the expulsion of those students. Upon review, the Circuit court overturned this case and ruled in favor of the students. Alabama State College is a public institution. As such, “whenever a governmental body acts so as to injure an individual, the Constitution requires that the act be consonant with due process of law.”
While the students may not have the right to pursue their education, the government may not prohibit their attendance “unless by means consonant with due process of law.” The panel also rejected the Board’s argument that a single provision in their regulations is enough to waive a student’s legal rights. Once again, as the institution is a governmental body– they cannot condition a privilege by stripping a person of their constitutional rights. Even if this issue were to be ignored, the provision itself is not clear enough in intent to be used as a waiver. In their opinion they wrote that private institutions could create waiver agreements in terms of due process, yet even those waivers are clear and explicit. In absence of this waiver, the State of Alabama requires a notice and a hearing before expulsion.
In correcting the District’s Court’s opinion, the fifth circuit wrote new precedent. It outlined the the process that the Board must follow to provide the students sufficient due process before the case was remanded back to the District Court.
Scope
Ofcourse, the State of Alabama filed a writ of certiorari in hopes that the Supreme Court (SCOTUS) would pick the case– but they left it in place, settling this matter. Although SCOTUS didn’t pick this case up, the fifth circuit’s reasoning was so persuasive that the other circuits began to draw from this case. In addition to this, the fifth circuit that held this case was much larger than our current version. The old circuit listened to the appeals of seven states, a population of 40 million. Twenty years after this case, Congress split the circuit in two and created the 11th circuit in response– so that precedent can be said to originate in two appellate courts before spreading throughout the entire country.
Dixon v. Alabama has been cited by 468 later decisions, with SCOTUS cementing this further by citing it six times in their decisions. It answered a question that courts were dealing with across the country during the civil rights era and had a clear structure. Even if those lower courts aren’t bound to the Fifth circuit, that opinion is still an appellate one–citing it saved them the effort of making their own arguments. The other appellate courts took this a step further by adopting the basic idea and then adding their own reasoning into it. This created national precedent even without the SCOTUS stamp of approval as each circuit adopted this reasoning in their own way.
A decade later, SCOTUS took Dixon v. Alabama and applied it to Goss v. Lopez, a case that expanded these due process rights to the K-12 education system– explicitly building upon this foundation.
Doctrine
Pre-Dixon, the doctrine of loco parentis allowed institutions to exercise authority over students in an broad manner. At the time, there were relatively few safeguards to protect students– so these institutions used it to keep a close leash on their students. Dixon ruled that this authority doesn’t supersede the Constitution and created procedural safeguards that undercut this doctrine. Students must receive a notice in advance and an opportunity to defend themselves. Instead of arbitrarily exercising this power, these governmental institutions must justify their actions when a student is harmed by it.
Afterword
This page is the consequence of sitting in a van for 5 hours. It was fun doing research but I had to rewrite my answer five times since i kept on adding all of this cool stuff instead of actually answering it.
Sources
- The Opinion of the Southern District of Alabama
- The Opinion of the Court of Appeals for the Fifth Circuit
Dixon v. Alabama State Board of Education, 294 F.2d 150 (5th Cir. 1961).View on OpenJurist →