Dress Not for Success: Fifty Years of American Dress Codes Burdening Students

Karnik Soghomonian
Professor Brauer
Writing 39C
February 16th, 2012
Dress Not For Success: Fifty Years of American Dress Codes Burdening Students
Over the past fifty years, dress code policies have been a major topic, a topic repeatedly protested against by American high school students. However, at the same time, dress codes have gained popularity in school districts across America. Since the 1960s, drastic measures have been taken to prevent students from wearing certain clothing of their choosing, in fear that the message presented on their clothing being too controversial. Consequently, students have been burdened with dress codes that infringe upon their First Amendment rights. This ongoing trend of imposing dress codes in schools has plagued America for years, resulting in numerous law suits and student punishments. The dress code debate in American Public schools can be traced through various inconsistent rulings in the court cases dating back to 1969, and continued to gain speed as a result of falsified information gathered to encourage dress codes in 1994. This debate has continued despite evidence suggesting its uselessness founded by Dr. David L Brunsma in 1998 and despite the negative psychological effects that dress codes could potentially cause, as implied by Psychoanalysis Erik Erikson in the 1960s.
Controversy over American public school dress code policies gained the nation’s attention in 1968, when a group of high school and middle school students attending schools at Des Moines Independent Community School District (DMICSD) in Iowa claimed that their personal rights were being violated in the American schooling system. According to the students, they had been suspended from their school for half a month for wearing black armbands at school protesting the Vietnam War. Their school had suspended them on the grounds of violating the school district’s dress code policy, which stated that no students were allowed to convey any type of message through their speech or their clothing. Due to what they felt was an overbreach of school codes into their rights, the students sued the school district on November 12th, 1968. In the months that followed, the case, now known as Tinker, et al v. Des Moines Independent Community School District, et al, 393 U.S. 503, reached the level of the Supreme Court. On February 24th, 1969, the Supreme Court ruled in favor of the students saying, “it can hardly be argued that either students or teachers shed their constitutional rights to freedom of speech or expression at the schoolhouse gate” (Tinker). A result of the court case was a set of rules now known as the Tinker Standard, which state that a school district cannot ban any students’ rights unless they can point to specialized evidence that the specific right caused a substantial disruption of education and school activities. The Tinker Standards also state that if a student’s clothing portrays a clear and easy to understand message, the school has no right to hide that message (Hudson 150). This is still the standard in which our court system is supposed to abide. However, as will be mentioned further, the Tinker Standard has been ignored almost completely for forty years by the American School System and the court system (i.d. 154).
One such case that ignored the Tinker Standard was Broussard v. School Board of Norfolk in 1992. A student wore a t-shirt bearing the message “Drugs Suck” to her middle school in Norfolk, Virginia. The student had worn the t-shirt several times to school previously; however on one occasion the student was stopped in the school hallway and sent to the principal’s office where the student was held for the remainder of the day, losing a full day of education. The student, with the assistance of the American Civil Liberties Union, sued the school district for overbreach. Even though the t-shirt had a plain and easy to understand message that ‘drugs suck,’ which should have been protected under the Tinker Standards, the court ruled in favor of the school, ignoring the positive message of the shirt insisting that the word ‘sucks’ was too sexual. The court ruled this, even though the school district had failed to provide any evidence of disruption of student education (Broussard).
In 1997, David Chalifoux and Jerry Robertson of New Caney High School in Texas wore rosary beads to school to express their Catholic faith. A school police officer told them to remove them due to their association with Hispanic gang culture. The two students, who had never associated with gangs before, looked through a student handbook which did not list rosaries as out of dress code. The students filed a lawsuit against the school, challenging the ban of rosaries in school with the application of the Tinker Standard. The court ruled in their favor, acknowledging that the school failed to provide evidence of the disruption of beads (Chalifoux). However, in recent times, it is seen that the Chalifoux case has also been ignored; in 2010, school officials in New York suspended a thirteen year old student for also wearing rosary beads while mourning the loss of his brother (Hudson 144). As can be seen, the legality of dress codes is entirely unclear as courts have contradicted themselves several times. The fact that the Tinker Standard is not widely accepted in all courts causes great confusion in laws of the First Amendment. Some courts, such as the one involved in the Chalifoux case, apply the Tinker Standard while other courts, such as the one in the Broussard case, do not. Some court cases make up their own standards such as seen in one example from Albemere County, Virginia where the court allowed students to wear t-shirt with guns to school, since the mascot of the particular school was a soldier carrying a musket (Hudson 155).
Proponents of school dress codes claim that data and evidence support their argument that dress codes and uniforms improve discipline and reduce the crime rates in school. Those in favor of dress code policies point to Long Beach Unified School District, the first district to have a widespread uniform dress code policy in its public schools in 1994. The initial reports show a drop in crime by seventy percent. While this report seems to show positive credence to dress codes, upon closer examination, problems begin to appear. In 1996, Dr. Kerry A. Rockquemore, a professor at the University of Notre Dame, took a closer look at the information gathered in Long Beach and noticed that several other reforms were put into place at the same time as the uniform dress code policy. Rockquemore’s examination conclude to a third variable problem, that while the change in dress code policy was the most obvious change, improvements to campus security through the increase of campus police officers and increase funding to improve teaching methods are most likely the cause of the drop in crime rates seen in long beach Unified School District (Williams). Despite the noted third variables found seen in the Long Beach statistics on dress codes, many school districts have adopted similar dress code policies and have consequently felt no positive results. For example, Miami-Dade County School District in Florida created a dress code policy similar to that in Long Beach in 2006 and in the following few years, saw in increase in student misconduct (i.d.).
In response to the popularity of dress code policies since Long Beach initiated theirs in 1994, Dr. David L Brunsma, currently a professor of sociology at Virginia Tech University, has devoted much of the last fifteen years to studying uniforms and dress codes in public schools and their effects on students. In 1998, Brunsma, along with Dr. Rockquemore of Notre Dame, published his first academic paper showing the results of uniforms and dress codes on student. The study was conducted by following hundreds of students across America that had been chosen for a previous experiment in 1988. Many of these students went to schools with dress code policies while many did not. Brunsma and Rockquemore compared the students and concluded that dress codes and uniforms had no effect on student behavior, academics, drug use, or attendance in school (Brunsma, David and Kerry Ann Rockquemore). The graph below taken from Brunsma’s book The School Uniform Movement and What it Tells Us about American Education published in 2004 as a follow up on his 1998 paper shows nearly identical results that were published in his 1998 paper. The graph shows the correlation coefficient of dress codes and uniforms to various variables thought to be affected by dress code policies. A correlation coefficient of + or – 1 would indicate a perfect correlation while 0 would indicate perfect no correlation, which rarely happens in the real world. As you can see in the graph from Brunmsa’s book, the correlation coeeficients are much closer to 0 than they are to + or – 1. This indicates that there is no significant correlation between dress codes or uniforms to any variables shown in the graph. Figure 1: Brunsma, David L.. The School Uniform Movement and What it Tells Us about American Education. Lanham, Maryland, United States of America: The Rowman & Littlefield Publishing Group, 2004. Print.13 Feb. 2012.
Figure 1: Brunsma, David L.. The School Uniform Movement and What it Tells Us about American Education. Lanham, Maryland, United States of America: The Rowman & Littlefield Publishing Group, 2004. Print.13 Feb. 2012.

With little evidence to support their claims, many schools still implement dress codes, which some psychologists insist is hurting the development of adolescents (Swafford). In 1968, Psychoanalysis Erik Erikson published his book Identify: Youth & Crisis detailing key psychological crises in adolescents’ life that lead to healthy development of personality and identity. In his book, Erikson describes one crisis in which an adolescent undergoes a series of physical transformations by changing their clothes, hair, body, etc. in order to explore various options in self-identity (Erikson 128). Erikson states in his book, “should a young person feel that the environment tries to deprive his too radically of all the forms of expression… he may resist with the wild strength encountered in animals…without a sense of identity.”(i.d. 130). Here, Erikson is saying that if an adolescent has this remodeling of physical appearance restricted, such as through dress code policies, an adolescent going into adulthood may develop psychological problems in his personality causing him to be no more like an animal than a human. Erikson goes on further to identify these animal-like disorders as idiosyncrasy, depression, identity confusion, negative identity, and in rare cases, dissociative identity disorder (formerly known as multiple personality disorder), and borderline personality disorder. Erikson’s theory of identity development in adolescents is still considered the leading theory in the development of human identity and personality, being taught in college still today (Henry). Despite the evidence drawn from Rockquemore’s and Brunsma’s studies, many schools are still ignorant of this information and still strongly believe that the results gathered from Long Beach are genuine. Assuming mainstream psychology is true, schools are potentially hurting students by preventing them to wear the clothing they want. Who knows how many adolescents have developed a poor self-identity because of their school’s dress code policy. There are many news stories and studies out there that claim that depression and identity disorders are on the rise in teenagers and young adults (Neighmond, Dissociative, and Cloud). Can this rise in identity disorders and depression be due to the rise of dress code policies? Something must be done to loosen dress code and uniform polices in schools. Surely, some form of code should be in place, but one that does not deprive students of their freedom of expression and identity. Perhaps America needs to go back to 1969, when the original Tinker Standards came out. It would seem that the Tinker Standard was meant to be followed by American public schools and the court system, rather than ignored and shelved only for occasional use.

Bibliography
Broussard v. School Board of Norfolk. Vol. 801 F.Supp. 1526 (E.D. Va. 1992). 1992.
CHALIFOUX v. NEW CANEY INDEPENDANT SCHOOL DISTRICT. Vol. 976 F.Supp. 695 (S.D. Texas 1997). 1997. 18 Feb. 2012.
"Dissociative Identity Disorder (formerly Multiple Personality Disorder)." Recurrent Depression. 12 Oct. 2006.Web. 19 Feb. 2012.
Brunsma, David and Kerry Ann Rockquemore. "Effects of Student Uniforms on Attendance, Behavior Problems, Substance Abuse, and Academic Achievement." The Journal of Education Research 92.1 (1998): 53-62. Web. . Google Scholar. Dr. David Brunsma, a professor of sociology at Virginia Tech, and Dr. Kerry Ann Rockquemore, the Executive Director of the National Center for Faculty Development & Diversity, argues throughout their research that dress codes and uniforms in public school systems have no effect on students ' behavior in school. Brunsma and Rockquemore construct a ten year long experiment proving that there is no connection between the way a student dresses and the way they turn out academically for a scholarly journal on education research. In order to further back up their research, Brusma and Rockquemore cite many other scholarly researchers who have studies dress codes in school who have come up with similar results. Brusma 's and Rockquemore 's audience can be narrowed to those in the field of educational research, or perhaps parents interested to find out if a school with a dress code policy is right for their child. Their central purpose is to dismiss the claim that dress code and uniform policies improve student behavior.
Brunsma, David L.. The School Uniform Movement and What it Tells Us about American Education. Lanham, Maryland, United States of America: The Rowman & Littlefield Publishing Group, 2004. Print.13 Feb. 2012. Dr. David Brunsma, a professor of sociology at Virginia Tech, argues that the use of dress code and uniform policies in public schools have had no effect on students ' behavior, grades, drug use, or violence. Brunsma tells his thesis in a book that summarizes over fifteen years of research of dress codes and uniforms. In order to prove that dress codes and uniforms have no effect on students, Brunsma cites numerous examples of school districts with failed uniform policies and tells of his own journey on testing students across the country to prove that there is no correlation between dress code and student behavior. Brunsma 's audience can be narrowed to those working in the education field and those who are interested to know more about dress codes and uniforms in the public school system. His central purpose is to explain away the common misconception that uniforms benefit students.
Brunsma, David L.. Uniforms In Public Schools: A Decade of Research and Debate. Lunham, Maryland, United States of America: Rowman & Littlefield Education, 2006. Print.13 Feb. 2012.
Cloud, John. "The Mystery of Borderline Personality Disorder." Time Magazine. 8 Jan. 2009.Web. 19 Feb. 2012.
Erikson, Erik H.. Identity Youth and Crisis. New York, New York, United States of America: W.W. Norton & Company, 1968. Print..13 Feb. 2012.
Henry, Gleitman, Gross James and Reisberg Daniel. "Psychology." . 8th ed. Ed. Sheri L. Snavely. New York, New York: W.W. Norton & Company, 2010. : 576-582. Print. 1 Feb. 2012.
Hudson Jr., David L.. Let The Students Speak! A History of the Fight for Free Expression in American Schools. Boston, Massachusetts, United States of America: Beacon Press, 2011. Print.13 Feb. 2012. David L Hudson Jr, a professor in law at Vanderbilt University Law School, Nashville School of Law, and Middle Tennessee State University, argues that students’ rights of freedom of expression are being violated in the American school system. Hudson constructs a historical analysis on students’ rights in school and their fight for freedom of expression. Hudson examines court cases, student protests, and other key events in the history of students’ fight for the freedom of expression in schools to tell the tug-of-war story between school officials and students. Hudson’s audience can be narrowed down to those interested in the First Amendment laws, and also the casual reader who with an interest in law and schools. Hudson’s central purpose is to explain the major events in the history of students’ fight for freedom of expression and to educate his audience on why the debate is so important.
Murphey, Paul D.. "RESTRICTING GANG CLOTHING IN PUBLIC SCHOOLS: DOES A DRESS CODE VIOLATE A STUDENT 'S RIGHT OF FREE EXPRESSION?." Southern California Law Review.64 (1991): 1321. Web.. 15 Feb. 2012.
Neighmond, Patti. "Depression On The Rise In College Students." National Public Radio. 17 Jan. 2011.Web. 19 Feb. 2012.
Swafford, Melinda, Ann Lee and Leigh Southward. "The Student Dress Code Debate (Part II)." Techniques: Connecting Education & Careers 86.2 (2011): 10-11. Web. 21 Jan. 2012. Academic Search Complete.
TINKER ET AL. v. DES MOINES INDEPENDENT COMMUNITY SCHOOL DISTRICT ET AL. 393 U.S. 503. 24 Feb. 1969. Web. 1 Feb. 2012.
Willaims, Darlene. "School Uniforms: The Raging Debate." . 2000. Web.. Asserting Parental Rights – it’s Our Duty.

Writer’s Memo
I really like the information that I was able to present in this paper. I feel like it is really convincing and strong evidence. If I had more time, I would just make it better. I would go back and see if I can make any sentences shorter and easier to read. For this essay, I really did not have too many opportunities to go back and review my work. I guess I would thank my class mated for reading my paper and Prof. Brauer for guiding us through the paper. I believe I will get a B+ in this paper.

Bibliography: Broussard v. School Board of Norfolk. Vol. 801 F.Supp. 1526 (E.D. Va. 1992). 1992. CHALIFOUX v "Dissociative Identity Disorder (formerly Multiple Personality Disorder)." Recurrent Depression. 12 Oct. 2006.Web. 19 Feb. 2012. Brunsma, David and Kerry Ann Rockquemore Cloud, John. "The Mystery of Borderline Personality Disorder." Time Magazine. 8 Jan. 2009.Web. 19 Feb. 2012. Erikson, Erik H. Henry, Gleitman, Gross James and Reisberg Daniel. "Psychology." . 8th ed. Ed. Sheri L. Snavely. New York, New York: W.W. Norton & Company, 2010. : 576-582. Print. 1 Feb. 2012. Hudson Jr., David L. Murphey, Paul D.. "RESTRICTING GANG CLOTHING IN PUBLIC SCHOOLS: DOES A DRESS CODE VIOLATE A STUDENT 'S RIGHT OF FREE EXPRESSION?." Southern California Law Review.64 (1991): 1321. Web.. 15 Feb. 2012. Neighmond, Patti Swafford, Melinda, Ann Lee and Leigh Southward. "The Student Dress Code Debate (Part II)." Techniques: Connecting Education & Careers 86.2 (2011): 10-11. Web. 21 Jan. 2012. Academic Search Complete. TINKER ET AL Willaims, Darlene. "School Uniforms: The Raging Debate." . 2000. Web.. Asserting Parental Rights – it’s Our Duty. Writer’s Memo