The length or style of your hair is an even more personal decision than what you wear, because you can change your clothes when you leave school. The Supreme Court noted in the Tinker case that it did not present questions about school rules governing dress or hair, and the court has avoided taking any case to decide if students have a constitutionally protected freedom to decide their personal appearance. The United States Court of Appeals for the Fourth Circuit with jurisdiction over Maryland decided in 1972 that students’ hair length is a kind of expression protected by the First Amendment - that is, wearing your hair is a statement of personal beliefs. [1]  School officials cannot limit that expression simply because they don’t like it.

In D.C. and Prince George’s and Montgomery Counties, the general dress codes found in the regulations don’t mention hair. And no court in this area has decided a case where a student challenged discipline based on a school rule limiting students’ hair, mustaches, or beards. As a general rule of thumb, schools must justify any hair, beard, or other grooming policy by demonstrating the limitation is necessary to prevent distraction or disruption, or to promote safety, cleanliness, and health.

[1] Massie v. Henry, 455 F.2d 779 (4th Cir. 1972)(striking down hair length guidelines in North Carolina high school as having no basis); also Breese v. Smith, 501 P.2d 159 (Alaska 1972)(finding law unclear on students’ right to free choice of hair style at school—reviewing cases from all federal circuits and finding courts divided; but finding right protected in privacy segment of Alaska state constitution); Holsapple v. Woods, 500 F.2d 49 (7th Cir. (Ill.) 1974)(right to wear one's hair at any length or in any desired manner is an ingredient of personal freedom protected by the United States Constitution).