Policy Report ERIC Clearinghouse on Educational Management ? University of Oregon 1 VIEWPOINT School Dress Codes and Uniform Policies by Wendell Anderson Opinions abound on what students should wear to class. But it?s not only the fashion mavens who express strong feelings about clothing. School-board members, school administrators, teachers, parents, and students also enter the debate. Some people believe that requiring students in school settings to conform to a dress code improves student behavior, reduces differences among socioeconomic levels, and enhances students? self-confidence. I N S I D E Why Dress Codes and Why Now? .................. 5 Facing Down the ?Fashion Police?......... 7 Research Findings: Uncertain Results ...... 9 Dress Codes and Case Law............................ 11 Dress Codes and School-Uniform Policies, State by State ..................... 13 Guiding Principles When Drafting a Dress-Code Policy .... 15 Conclusion ................ 18 Bibliography ............. 19 SIDEBARS Principals Speak Out .................... 3 Advantages of a Standard Dress Code ... 5 Disadvantages of a Standard Dress Code ... 7 Recommendations for Researchers.................. 9 Some Practical Advice ....................... 11 Factors Affecting Dress- Code Challenges ........ 12 Sample Dress Code.... 16 Divided Camps Although the research data don?t show an abso- lutely clear link between dress and students? behav- ior or performance, anec- dotal evidence?and cer- tainly many people?s per- ceptions?generally sup- port some type of dress code in elementary, middle, and high schools, according to one camp?s view. The idea of school uni- forms also appeals to many parents and teachers, espe- cially in elementary and middle schools. Uniforms ?are seen as a concrete and visible means of restoring order to the classrooms. Uniforms conjure up vi- sions of parochial schools, which are perceived as safe, secure, and orderly learning environments? (Education Week 2001). Others say that policies stipulating dress codes or requiring school uniforms infringe upon students? First Amendment rights, stifle individuality, and im- pose unnecessary means of control. The argument over school dress codes and school-uniform policies continues to rage in the meeting rooms, administra- tive offices, and class- rooms of public schools throughout the country. Two fundamental questions fan the fires of debate: Are restrictive dress codes a sound idea in a soci- ety that, theoretically at least, celebrates diversity over uni- formity? Do dress codes and school-uniform policies de- crease school violence and increase performance? This [dress code] has been something we?ve been working on for five years now. We didn?t have a big problem before. We?re just being more rigid about it.? ?Patricia Pitt, assistant principal, Old Mill Senior High School, Millersville, Maryland ? Wendell Anderson is a research analyst and writer for the ERIC Clearinghouse on Educational Management. POLICY REPORT Number 4 REPORTING ON POLICY ISSUES IN K-12 EDUCATIONAL MANAGEMENT Fall 2002 ERIC Clearinghouse on Educational Management University of Oregon 2 2 2 2 2 ERIC Clearinghouse on Educational Management University of Oregon Policy Report Policy Report Number 4, Fall 2002 Reporting on Policy Issues in K-12 Educational Management ERIC Clearinghouse on Educational Management Professor and Director: Philip K. Piele Editorial Director: Stuart C. Smith Author: Wendell Anderson Designer: Leeann August CLEARINGHOUSE NATIONAL ADVISORY BOARD Anne L. Bryant, Executive Director, National School Boards Associa- tion Vincent L. Ferrandino, Executive Director, National Association of Elementary School Principals Patrick B. Forsyth, Vice-President, Division A, American Educational Research Association Paul Houston, Executive Director, American Association of School Administrators Philip K. Piele (Chair), Professor and Director, ERIC Clearinghouse on Educational Management, University of Oregon Ted Sanders, President, Education Commission of the States Gerald Tirozzi, Executive Director, National Association of Secondary School Principals Michelle Young, Executive Director, University Council for Educational Administration Additional copies of this publication will be available while supplies last. Copies are $3.00. Address orders to: Publications Department ERIC/CEM 5207 University of Oregon Eugene, OR 97403-5207 Telephone (541) 346-5044 (800) 438-8841 Fax (541) 346-2334 This report is in the public domain and may be freely copied and reprinted in whole or in part with proper credit. The full text is also available at eric.uoregon.edu This publication was prepared in part with funding from the Office of Educational Research and Improvement, U.S. Department of Education, under contract no. ED-99-C0-0011. The opinions expressed in this report do not necessarily reflect the positions or policies of the Department of Education. The University of Oregon is an equal opportunity, affirmative action institution committed to cultural diversity. In the other camp are some parents, civil libertarians, and students, particu- larly older ones, who oppose dress codes in general and uniform policies in particular. ?Critics point to the fact that uniform requirements cramp stu- dents? freedom of expression and amount to nothing more than a band- aid [sic] solution to the illness that ails our schools. They also point to the fi- nancial burden uniforms put on lower- income families? (Wills 2001). This Policy Report examines the issue of school dress codes and uniform policies from a variety of perspectives. The section below presents a brief his- tory of dress codes and uniforms, fo- cusing on the last fifteen years. On pages that follow, the report examines the motivations behind establishing dress codes in light of recent events and presents arguments for and arguments against dress codes and uniforms. Because so many legal issues have been raised over dress codes and uni- forms, this report also examines some of the legal actions and important court decisions regarding restrictive dress codes and uniforms. And finally, the report offers suggestions and guide- lines from a variety of sources for de- veloping, implementing, and enforcing school dress codes and school-uniform policies. Fashion Show: A Brief History of Dress in Schools The presumption, variously ex- pressed, that dress affects behavior and performance is, of course, not a new one. ?Clothes make the man.? ?The apparel oft proclaims the man.? ?Good clothes open all doors.? ?Beware of all enterprises that require new clothes.? The dictum ?Dress right, act right? was heard often in schools in the 1950s and ?60s during campaigns to curb ?ju- venile delinquency.? In the 1950s, many school dress codes prohibited girls from wearing slacks. In the 1960s, many school administrators stipulated the length of girls? skirts. Blue jeans, motorcycle boots, and black leather jackets were considered dangerous at- tire on boys and linked to gangs. In the 1980s, an effort to thwart growing gang activity in schools led school officials to reexamine their schools? dress codes and consider poli- cies requiring uniforms. Restrictive dress codes were introduced in many secondary schools with the intent of prohibiting gang attire. ?These efforts have taken on a sense of considerable urgency in areas where gang activity threatens the safety of the school envi- ronment. Though gang members are known to intimidate others in various ways, their clothes have been a primary form of gang member identification? (Lane and others 1996). Public school districts and indi- vidual schools have long established dress codes proscribing certain cloth- ing. The first public school known to have adopted uniforms was Cherry Hill Elementary in Baltimore, Maryland, in 1987. In 1994, Long Beach (CA) Uni- fied School District (LBUSD) was the first school district to adopt a districtwide uniform dress code policy. The idea of dress codes and uni- forms gained official sanction when President Clinton endorsed the idea of public-school uniforms in his 1996 State of the Union Address. Following Clinton?s direction, the U.S. Depart- ment of Education mailed A Manual of School Uniforms to all 16,000 school districts in the United States. VIEWPOINT We don?t have mandatory uniforms, but we do have a very strict dress code that includes all collared shirts that are to be tucked in. But since the only shorts we allow are uniform shorts, a lot our students end up wearing at least one part of the uniform on a regular basis.? ?Rod Federwisch, principal, Anna Borba School, Chino, California ? Policy Report ERIC Clearinghouse on Educational Management University of Oregon 3 With guidelines in hand, school boards and administrators began to de- velop dress codes and uniform policies. By 1999, 72 percent of New York City?s 675 elementary schools had a standardized dress code. In 2000, the Philadelphia School Board unanimously adopted a districtwide policy requiring some type of uniform. By 2000, in Miami, 60 percent of the public schools required uniforms; in Chicago, 80 percent. By 2000, 30 percent of the public schools in San Francisco, 50 percent of the schools in Cincinnati, 65 per- cent in Boston, 85 percent in Cleve- land, and 95 percent in New Orleans had school-uniform programs. Also by 2000, 37 state legislatures, including those in California, Florida, Georgia, Indiana, Louisiana, Maryland, New York, Tennessee, Utah, and Virginia, had enacted leg- islation empowering local districts to set their own uniform policies. (Mor- ris and Wells 2000) It?s not clear how many districts and schools now enforce a dress code or uniform policy. But the trend toward proscribing and prescribing what stu- dents wear to class continues to grow, along with the debate. Codes and Policies: Dressing Up Dress codes and uniform policies are not the same. Simply stated, dress codes state what must not be worn; uni- form policies state what must be worn. The distinction is important, particu- larly in light of legal challenges. For example, dress codes that prohibit the wearing of clothing or symbols linked to gangs have been traditionally upheld by the courts, whereas uniform policies Principals Speak Out In 1999, three researchers set out to gather opinions on dress codes from school principals. They polled 240 principals chosen randomly from a national directory. Their sample was equally di- vided among principals of elementary, middle, and high schools. More than 60 percent of the principals responded; some even sent copies of their dress codes for the researchers to analyze. Follow- ing are some of the results of the survey: About 85 percent of the principals believed that some sort of dress code was needed at their school. More than half the principals said their schools had formally adopted a dress code. Most principals believed that dress codes improve student behavior, re- duce peer sexual harassment, prepare students for the work world, and are worth the effort it takes to enforce them. Middle-school principals expressed the strongest support for mandatory uniforms. High-school principals stated the strongest support for dress codes but were less enthusiastic about uniforms. Principals in rural areas showed greater support for dress codes than prin- cipals in suburban and urban schools. Urban principals showed greater support for uniforms, followed by subur- ban and rural principals. 000000000000000 SOURCE: DeMitchell, Fossey, and Cobb (2000) are sometimes viewed as violations of students? rights. But uniform policies adopted to minimize gang-related violence are often viewed as issues of safety and upheld by the courts. (See ?Dress Codes and Case Law? in this Policy Report.) The debate over what to wear at school has many levels and subplots. Officials in a number of districts and schools in recent years have tem- pered their approaches by enacting VIEWPOINT Ithink [the dress code] is starting to lean more to girls because they have more clothing. To a certain extent, girls show more skin.? ?John Russell, student, Old Mill Senior High School, Millersville, Maryland ? 4 4 4 4 4 ERIC Clearinghouse on Educational Management University of Oregon Policy Report stricter dress codes rather than forcing the wearing of uniforms. School offi- cials in Fayette County, suburban At- lanta, Georgia, for instance, decided in favor of a tighter dress code in 1999 in response to community demands (White 2000). The Marple Newtown School Dis- trict in Newtown Square, Pennsylvania, chose a dress code rather than uni- forms. The fairly typical code prohib- its the wearing of tube tops, halter tops, cutoff shorts, short shorts, and clothes that promote alcohol or drugs. ?Going from a loose dress code to school uni- forms seemed like a knee-jerk reac- tion,? said Raj Chopra, superintendent of the suburban Philadelphia school system. ?It seems like an easy solution, but our goal was to get students to dress for success? (in White 2000). But the solution remains far from easy. There are many layers to the de- bate. Adapting to Changing Fashions Some people claim that dress codes focus too much on girls? fashions be- cause girls? fashions change more of- ten than boys? do. In a much publicized ?fashion show? in September 2001 at Old Mill Senior High School in Millersville, Maryland, the outfit worn by senior Katrina Howard turned heads with her ?inappropriate? attire: jeans cut with horizontal vents from waist to ankles and a midriff-baring one-strap halter top (Bowman and Bushweller 2001). The third annual Old Mill Fashion Show was an opportunity for adminis- trators to display acceptable and unac- ceptable student dress as described in the school?s dress code. Girls? fashions attracted the most attention. At the time, skin was in. But the Old Mill Se- nior High School dress code prohibited the wearing of tops and jeans that re- veal too much skin. For boys, Old Mill?s dress code prohibited pants sag- ging to reveal underwear, cutoff T- shirts, tight skullcaps, and various techno-toys such as cell phones. Part of the problem schools face with implementing dress codes is that youth fashions change frequently and radically. It?s difficult for administra- tors to keep up; therefore, many schools adopt general dress codes. John Brucato, principal of Milford High School in Milford, Massachu- setts, described to CNN his school?s dress code, which seems to encapsu- late the principles in many dress codes: We ask our students to dress and groom themselves as individuals with a sense of responsibility and self-respect. So, it? hat you must wear; it? hat we don?t feel is appropriate. Specifically, if it becomes disruptive, offensive, threat- ening, or provocative to others, is vul- gar, displays tobacco or alcohol adver- tising, profanity, racial slurs, has disrup- tive images of gang-related symbols. (Brucato in CNN.com 2001a) In some respects, school-uniform policies are easier to maintain than dress codes. Part of the acceptance of uniforms has to do with style. The style of today?s uniforms is more relaxed to suit the times. The traditional blazer, PR white blouse, plaid skirt for girls and dark slacks, white shirt, school tie for boys are still seen. But more modern styles such as white T-shirts with blue jeans, denim shirts or skirts, and khaki pants with cargo pockets are not un- common. French Toast, the largest manufacturer of school uniforms, fea- tures more than 4,000 uniform items. After President Clinton called for uniforms in his 1996 speech, many schools answered the call. And manu- facturers and retailers also jumped on the bandwagon. In 1999, American families spent some $1.5 billion on uniforms (Marchant 1999). Major re- tailers such as Sears and Kmart stock uniforms. About two-thirds of uniforms are sold during the annual ?back-to- school? season (BlueSuitMom.com 2000). But while the debate over dress codes and school uniforms rages, there is one point almost everyone agrees on: Student dress does not cause or will not cure all the ills facing our schools. Implementing a dress code or uniform policy should be only one of several changes designed to improve standards in schools, said Jay Goldman, editor of School Administrator. A dress code ?as part of a wider array of policies and practices is probably a very good thing,? he said. ?If done as a supposed quick fix, it is a terrible idea. Nothing is a quick fix in education? (Goldman in Marchant 1999). VIEWPOINT When parents come to enroll their children, we tell them right away that we?re a uniform school, and they say, ?We know, we?re happy about it.? Teachers and parents love the fact that we have uniforms. The children . . . Well, that?s a different story.? ?DeLores Wilson, principal, Poplar Halls Elementary, Norfolk, Virginia ? Policy Report ERIC Clearinghouse on Educational Management University of Oregon 5 Why Dress Codes and Why Now? Arguments for dress codes and uniforms policies stress school safety. If you were to ask administrators and teachers to prioritize a list of concerns, what children wear to school would likely be ranked low, below funding, school violence, and even what color to paint the walls of the staff lounge. So why all the fuss about dress codes and uniform policies? Clearly, as Lumsden (2001) pointed out, it is naive to think of a dress code or uniform policy as the sole solution to the problems that plague schools. Nevertheless, a well-con- ceived dress code coupled with other appropriate interventions could have a positive impact on a school?s social en- vironment. Supporters of dress codes or uni- form policies have compiled a long list of the perceived advantages of stan- dardized dress in the classroom.The list can be shortened to four basic benefits: 1.Enhanced school safety 2.Improved learning climate 3.Higher self-esteem for students 4.Less stress on the family Safety First A sincere concern with safety has been the overriding impetus toward the implementation of dress codes and uni- form policies. Many educators, and also people in the community, firmly believe that if everyone in school dresses alike, or at least dresses simi- VIEWPOINT Ithink you?re going to see an increased emphasis on more standardized dress escalating as a result of Littleton.? ?Paul Houston, executive director, American Association of School Administrators Advantages of a Standard Dress Code In 2001, the Clarksville-Mont- gomery County (TN) School System surveyed the local community con- cerning dress-code issues. Results of the survey revealed the follow- ing perceived advantages: Diminishes exclusion of students based on what they are wearing. Places stronger focus on academic performance. Decreases opportunity for showing gang affiliation or hiding weapons. Reduces family tension; saves time in the morning. Decreases participation in violent activity. Leads to higher academic perfor- mance. Creates atmosphere of teamwork and pride in personal appearance and school. Promotes safety; makes it easier to identify strangers in schools. Increases self-esteem and reduces peer pressure. Most cost effective to parents in the long run. Reduces absenteeism. Puts students on a more common ground. Reduces discrepancies in adminis- tering dress-code justice. 000000000000000 SOURCE: Adapted from Clarksville- Montgomery County (TN) School System larly, there will be less violence. There is a general perception that most stu- dents will behave the way they are al- lowed to dress. Supporters of regulated dress maintain there is a definite connection between clothing styles and school vio- lence. For many students, an image? or sometimes stigma?is attached to certain styles, most notably gang-style clothing. Students have become targets of intentional or unintentional violence simply for wearing a particular type of shirt or cap or color combination af- filiated with a particular gang (King 1998). A popular style, especially with boys, is baggy pants and oversized shirts. This style is closely associated with inner-city gang members, who wear the loose-fitting clothes to better hide weapons and drugs, which can also be carried into schools. ?Add to this the finding that one in three youth reports easy access to handguns, and the concern for school safety becomes especially crucial? (King 1998). Curbing gang-related problems was the primary goal of the Long Beach (CA) Unified School District (LBUSD) when it established its pioneering districtwide uniform policy in 1994. ?Gangsta? is not the only style linked to violence. After the Columbine shootings, a certain stigma was at- tached to students wearing black trench coats, all black clothing, or black lip- stick and eye shadow. Many school dress codes banned black clothing and makeup. Ronald Stephens, executive director of the National School Safety Center, stated, ?In the wake of school shootings, communities and schools are much more willing to embrace uni- forms as well as a number of other strategies to enhance student safety? (in White 2000). ? 6 6 6 6 6 ERIC Clearinghouse on Educational Management University of Oregon Policy Report Dress codes prohibit the wearing of clothing that could be disruptive. As the director of a charter school said, ?It doesn?t bother me to say that we ban bare midriffs in our school not because we think they are vulgar or offensive.... We ban bare midriffs because we see them as unwelcome and unnecessary distractions that can divert too much student attention from the serious in- tellectual work we?re here to do to- gether? (Northrop 2002). Uniforms set the tone for a proper attitude toward work. Uniforms remind students that they are in school to learn, not to make a fashion statement. Other potential benefits attributed to uniforms that help enhance perfor- mance include improved discipline, increased respect for teachers, in- creased school attendance, fewer dis- tractions, and improved classroom be- havior (Lumsden 2001). Peer Pressure Dressing for success is a practice witnessed not only in the office but also in the classroom. A flair for fash- ion has always paid big dividends. Clothes do make the man, or woman. ?Middle school students can sometimes be cruel. If a child does not have the ?right? brand or style of clothing, stu- dents can make life very difficult for that student? (Kahl 1997). By removing the status that cloth- ing labels accord some children, a uni- form becomes a great equalizer. A uni- form also conceals the income of a child?s family, thus eliminating another mark of distinction or shame. An at- tractive uniform promotes school spirit and good self-image, just as athletic team uniforms promote spirit and unity. By eliminating the preoccupation of status brought about by dress, propo- nents say, students can find more pro- ductive and creative outlets to express their individualism. No child should become a Barbie or Ken doll to dress and undress accord- ing to the style of the month. With chil- dren, we really ought to hold on to some conservative old certainties?for ex- ample, the notion that how you dress is ultimately far less important than what and how you think. That? school systems send when they require school uniforms. (Northrop 2002) PRPRPRPRPR Family Values When dress codes or uniform poli- cies are instituted, many families real- ize an immediate benefit: not having to buy so many expensive clothes for their fashion-conscious children. Some comparisons show that the cost of uni- forms is significantly less than the cost of the latest fashions. Many parents also welcome dress codes and uniforms because they bring added peace to the home. If what their children wear to school is predeter- mined, it becomes one less battle to fight in the morning. Kristi Kahl, who was a middle- school teacher during the first year of the implementation of the uniform policy at Long Beach USD, spoke of another hidden benefit to the family, as well as to the school: Do uniforms generate parent participa- tion? I believe they have. It is certainly something that almost everyone loves to talk about (whether they are pro or con)! I think that our teachers and site administrators have had the opportunity to meet parents who, without questions about the uniforms, might not have con- tacted the school. This allows conver- sations about other deep issues to de- velop. (Kahl 1997) VIEWPOINT Many families in our school really support our switch to uniforms. They say it?s easier and less expensive, and that the children look nicer. It also takes the attention off what someone else is wearing and solves the question, ?What am I going to wear today??? ?Nancy Dickerson, principal, Mattahunt Elementary, Boston, Massachusetts VIEWPOINT Uniforms have been a great equalizer for our students and have been wonderful both in terms of unity and discipline within the school and cost effectiveness for the parents.? ?Connie Jo Gamble, principal, Loxley Elementary, Loxley, Alabama Even seemingly ordinary fashions can invite violence. Children have been robbed of their expensive shoes and killed for simply wearing the wrong jacket: Children?s hunger to be fashionable brings another dimension to the connec- tion between clothing styles and school violence. Children may envy other children? clothing and lack the finan- cial resources to purchase similar styles. Subsequently, children have been vio- lently injured or even murdered for their designer clothes, sneakers, or profes- sional sport-team paraphernalia. School uniforms may reduce these occurrences. (King 1998) Furthermore, requiring students to dress alike could send the message that they are all on the same team. Viewing their fellow students as ?teammates,? they should be less likely to commit acts of bullying or other kinds of vio- lence against one another. Enhanced Performance Students who feel safe, secure, and free from threats of violence naturally perform better academically. Enhanc- ing academic performance is another argument in favor of adopting dress codes or uniform policies. Proponents believe that dress codes in general and uniforms in particular help students focus on their school- work, instead of on what they and oth- ers are wearing. ? ? Policy Report ERIC Clearinghouse on Educational Management University of Oregon 7 Facing Down the ?Fashion Police? Students who oppose dress codes and uniform policies have support among educators and civil libertarians willing to take their case to court. Together they decry the spread of ?fashizm.? A demonstration by students of Brookfield East High School in Milwaukee, Wisconsin, on a warm April morning served as a microcosm of the broad issues of and opposition to dress codes. As reported by Gehl (2002), twenty-five students, mostly girls, pa- raded in front of the school in protest of the administration?s recent stepped- up enforcement of its dress code. The code prohibited, among other items, clothing that revealed too much skin. Current fashion trends (skin was in) and a hot spell brought out some of the banned clothing, notably low-cut pants and thin-strapped tank tops that re- vealed bare midriffs. The administration?s reactions were imme- diate and predictable: Students were sent home to change into more ?appro- priate? attire and threatened with sus- pension. At the demonstration, one senior girl claimed the school administration overreacted to the problem of exposed stomachs and backs, which were in fashion that season. She further stated that students felt threatened by the rigid enforcement of the dress code and the consequences of violating it (Gehl 2002). Administrators asserted that the purpose of the dress code was to limit distractions and disruptions in the school setting. Many students did not see the need for the new dress policy and took issue with the motives behind it. ?Being hot in our school is way more distracting than a spaghetti-strap tank top,? said one senior girl. ?I want to see a statistic that shows this policy has helped grades go up,? said another (Gehl 2002). These students and their actions and comments captured the essence of opposition to dress codes and uniform policies, which revolves around two ba- sic points: 1.Dress codes and uniform policies are shallow solutions to deeper prob- lems. 2.Dress codes and uniform policies deprive students of fundamental free- doms. Problems More Than Skin Deep Critics claim that strict dress codes and uniforms offer a simplistic ap- proach to preventing school violence and other problems. ?While most par- ents and teachers seek to ensure the safety and security of their school chil- dren, some believe adopting a manda- tory school uniform policy is not the appropriate method for ensuring such safety? (King 1998). Older students, the most outspoken challengers to dress codes and uni- forms, have received support from the American Civil Liberties Union (ACLU). As far back as March 1996? only two months after President Clinton expressed support for uniform policies, which prompted the experi- ments of recent years?Loren Siegel, director of the public education depart- ment of the ACLU, wrote: If policy makers are serious about finding solutions to the problem of school violence, maybe they should ask the real experts: the students them- selves. The ACLU recently conducted a series of focus groups and discus- sions with high school students and asked them what they thought would help. Uniforms didn?t even make it onto the list. Their suggestions: 1. Since school violence mirrors that of society at large, schools should Disadvantages of a Standard Dress Code In 2001, the Clarksville-Mont- gomery County (TN) School Sys- tem surveyed the local commu- nity concerning dress-code is- sues. Results of the survey re- vealed the following perceived disadvantages: Requires an initial expense of purchasing the clothes. Leads to inconsistent enforce- ment of the dress code in schools systemwide. Causes problems with noncom- pliance. Infringes on freedom of choice. Hurts families who may not be able to afford it. Causes everyone to look the same. Becomes difficult to enforce in areas that are extremely transient. May contribute to negative be- havior such as rebelliousness. 000000000000000 SOURCE: Adapted from Clarksville- Montgomery County (TN) School System 8 8 8 8 8 ERIC Clearinghouse on Educational Management University of Oregon Policy Report seriously confront and discuss is- sues of racism and cultural con- flict. 2. ?Safe corridor? programs should be supported to protect the safety of students as they go to and from school. 3.School entrances should be se- cured. 4. More extracurricular activities and clubs should be established. 5. Open-mike assemblies should be held on a regular basis to give stu- dents the opportunity to express themselves. 6. Programs to help students find part-time jobs should be estab- lished. 7.Conflict resolution techniques should be taught. (Siegel 1996) Siegel went on to write that debate over uniforms is a diversion and that resources should be directed toward creating more attractive, clean, and safe school buildings; smaller classes; well-stocked libraries; new computers; and more elective courses such as mu- sic and art. Basic Freedoms at Risk Opponents argue that restrictive dress codes and uniform policies sup- press students? freedom of self-expres- sion, not to mention their spirit of cre- ativity and individualism. There are too many clones in the adult world already, they contend. Some believe that school uniforms are analogous to prison uni- forms and cause students to feel en- trapped. They also point to the loss of freedom of parents. Schools that im- pose dress codes or uniform policies dictate to parents how they should raise their children. When asked, ?What is the harm in dress codes?? on a CNN.com chat room, Nadine Strossen, then president of the ACLU, answered: The harms are many. From a free speech point of view, they prevent students from expressing themselves, either di- rectly, such as through a tee-shirt [sic] that contains a message, or indirectly, by conveying attitudes through apparel. In addition, dress codes violate parents? rights to make basic decisions about the upbringing of their children. Finally, as courts have agreed with us in many cases, dress codes violate religious be- liefs and freedoms of particular parents and students. (Strossen in CNN.com 2001b) As Lumsden (2001) reported, sev- eral legal challenges to dress codes and uniform policies have asserted that stu- dents? freedom to choose what to wear to school is, indeed, a form a self-ex- pression that schools have no right to infringe upon. (See ?Dress Codes and Case Law? on page 11.) Opponents also point to a lack of conclusive evidence that dress codes have had a positive effect on behavior and academic performance. ?All we have are self-serving, anecdotal reports from particular schools that have pro- PR VIEWPOINT Aside from reading and writing, public schools are supposed to be teaching democracy. Uniforms are antithetical to teaching people how to make choices.? ?Stefan Presser, legal director, American Civil Liberties Union of Pennsylvania VIEWPOINT The assistant principals won?t listen. They yell, ?Just do it! Do it now!?? ?Damir Abdurahamnovic, student, Hillcrest High School, Dallas, Texas VIEWPOINT First they threatened to suspend me for three days, but there was no way I could miss school for a dress-code issue.? ?Jacklyn Lipovsek, student, Brookfield East High School, Milwaukee, Wisconsin ? ? ? moted dress codes and are, not surpris- ingly, trying to justify them? (Strossen in CNN.com 2001b). Finally, foes of uniforms note that virtually all uniform policies are in place in elementary and middle schools, even though uniforms are pro- moted as a means to halt violence among older teens. Few attempts have been made to implement uniform poli- cies in public high schools because they would almost certainly be met with resistance from students ap- proaching adulthood and determined to make their own decisions. Even dress codes in public high schools are not always readily accepted, as the students of Brookfield East High School re- cently demonstrated. Policy Report ERIC Clearinghouse on Educational Management University of Oregon 9 Research Findings: Uncertain Results Empirical research on the effects of dress codes and uniforms offers little guidance. So far, research on the effects of dress codes and school-uniform policies is inconclusive and mixed. No clear trends have emerged. Some researchers claim positive effects, and oth- ers claim no effects or, at best, perceived effects. Following is a summary of some of the major studies on dress codes and uniform policies. The studies are pre- sented in chronological order. A 1995 study, ?Violence and Other Antisocial Behav- iors in Public Schools: Can Dress Codes Help Solve the Problem?? (by Lillian Hol- loman, in White 2000), inves- tigated the effectiveness of dress codes. The study identi- fied the problems that students can get into because of their Achievement,? empirically tested claims made by uni- form advocates, using tenth- grade data from the ?National Educational Longitudinal Study of 1988.? Researchers David Brunsma and Kerry Rockquemore succinctly stated: ?Our findings indicate clothes and found that gang- related clothing, worn inten- tionally or unintentionally, can invite violence. Also, status clothing such as team jackets and designer sneakers can lead to theft and violence (in White 2000). In 1995, a year after implementing the first manda- tory districtwide uniform policy in the country, the Long Beach Unified School District collected empirical data on the effects of uniforms on the school environment. The find- ings suggested that the district?s schools were safer; however, the findings did not offer clear evidence that uni- forms decreased violence (Wilson 1999). A 1996 study titled ?School Uniforms and Safety? found that school uni- forms ?reduce the emphasis on fashion wars and reinforce the acceptability of more prac- tical, less costly school cloth- ing.? The researcher, M. Sue Stanley, also concluded that uniforms may have a positive effect on school safety, and, because they are a low-cost in- tervention unlikely to do harm, are worth considering (in White 2000). A 1997 study, ?Effects of Student Uniforms on Atten- dance, Behavior Problems, Substance Use and Academic Recommendations for Researchers ?Lack of empirical evidence supporting school uniforms does not mean that school uniforms do not work? (King 1998). King made the following recommendations for researchers examining the effectiveness of school uniforms in preventing or reducing school violence: Focus on the means to adequately evaluate the effect of uni- form policies on school violence. Conduct studies that investigate parents?, teachers?, and stu- dents? perceptions of uniforms and violence prevention. Apply trend analyses to determine if any decline in violence represents true change or predictable change. Be sure studies specifically control for possible intervening variables associated with violence reduction to determine cause-and-effect relationships between uniforms and reduced violence. Compare the prevalence of violence in schools that have uni- form policies with schools that have dress codes. Gather data from experimental groups (subjects required to wear uniforms) and control groups (subjects not required to wear uniforms). Examine how schools that require uniforms address the is- sue of providing uniforms for families that may not be able to afford them. (King 1998) that student uniforms have no direct effect on substance use, behavioral problems or atten- dance? (Brunsma and Rock- quemore 1998). In 1997, Sharon Sham- burger Pate investigated two Florida school districts with VIEWPOINT I have never seen any study that showed a connection between style of dress and academic achievement.? ?Pedro Aoguera, professor of education, University of California at Berkeley ? 10 ERIC Clearinghouse on Educational Management University of Oregon Policy Report mandatory uniform policies. In ?The Influence of a Man- datory School Uniform Policy,? she reported mixed results: a significant improve- ment in academic achieve- ment in elementary-school students and no significant de- crease in discipline infractions among middle-school stu- dents (Pate 1999). A 1997 policy study, ?School Violence Prevention: Strategies To Keep Schools Safe,? conducted by the Rea- son Public Policy Institute, ex- amined how uniform policies fit into a school district?s over- all safety and reform program. Researchers Alexander Volokh and Lisa Snell con- cluded that no single strategy to curb school violence and promote reform will work. Each district, each school is unique. The ideal violence- prevention policy will differ from school to school (in White 2000). In 1999, a report titled ?Evaluation of School Uni- form Policy at John Adams and Truman Middle Schools for Albuquerque Public Schools,? by Deborah Elder, concluded: ?The uniform policy is one of several changes that have occurred in the two schools. While the impetus for positive change in the climate and academic fo- cus on the school includes the uniform policy, the changes cannot be attributable solely [author?s italics] to the uni- form policy. However, posi- tive changes have indeed oc- curred, and the uniform policy is one of several variables that have caused the changes? (El- der 1999). that dress codes or uniform policies are implemented. ?Because no long-term em- pirical studies have been conducted to assess the ef- fectiveness of school uni- forms or specific dress codes, the results remain anecdotal and unproven? (Morris and Wells 2000). Almost everyone, how- ever, agrees that more stud- ies are needed. PR VIEWPOINT Everyone I?ve talked to who has gone to uniforms likes it, felt it?s increased discipline and respect, and will even claim achievements have gotten a little better because kids are more focused on their studies.? ?Paul Houston, executive director, American Association of School Administrators VIEWPOINT [With uniforms] schools have fewer reasons to call the police. There?s less conflict among students. Students concentrate more on education, not on who?s wearing $100 shoes or gang attire.? ? William Ellis, police chief, Long Beach, California In 2000, Lands? End, the clothing retailer, in partner- ship with the National Asso- ciation of Elementary School Principals, commissioned a telephone survey of principals that netted 755 responses. About one-fifth (21 percent) of the principals said their schools either have a school- uniform policy in place, are preparing one, or have one on their agenda for discussion. According to the principals surveyed, school-uniform policies had a positive effect on the following areas: image in the community (84 percent of principals surveyed); class- room discipline (79 percent); peer pressure (76 percent); school spirit (72 percent); concentration on schoolwork (67 percent); and school safety (62 percent) (NAESP 2000). In 2000, a survey by French Toast, a uniform manufacturer, reported that in New York City a year after dress codes were imple- mented, 68 percent of parents thought that uniforms helped improve the overall academic performance; 84 percent of parents said uniforms pro- moted equality between the sexes; 89 percent of guidance counselors thought that uni- forms helped prepare students for an eventual work environ- ment; and 59 percent of guid- ance counselors said the uni- form policy created a safer learning environment (BlueSuitMom.com 2000). Conclusion Many educators and re- searchers point out that, though there may be de- clines in school violence and improvements in academic performance, it is difficult to attribute such results to dress codes or uniform poli- cies. Other reforms are of- ten enacted at the same time VIEWPOINT There is absolutely no evidence documenting even a correlation between dress codes and better test scores, let alone a causal connection.? ?Nadine Strossen, president, American Civil Liberties Union ?? ? Policy Report ERIC Clearinghouse on Educational Management University of Oregon 11 Dress Codes and Case Law When administrators turn to the body of existing case law for guidance in matters pertaining to student dress, they may be disappointed to discover that the legal decisions do not clearly specify what is proscribed and what is prescribed. The social and political winds have shifted since the first student-expression case was heard by the U.S. Supreme Court more than thirty years ago. These changes have often been reflected in the philosophical posi- tion of the courts. According to Majestic and colleagues (1995), in general there has been an ?increasingly deferential stance of the courts to the authority of schools in more recent years? compared with the more liberal climate of the 1960s and the ?judicial confusion? of the 1970s. Some Practical Advice Benjamin Dowling-Sendor, an authority on school law and an assistant appellate defender in North Carolina, offered this counsel to school boards wish- ing to adopt a school-uniform policy: Solicit input from parents and students. Research the experiences of other school districts with uni- form policies. Articulate the interests they wish to promote through uniform policies. Report on that process in a con- cise, written public statement by the board before you have to do so in court. SOURCE: Adapted from Dowling-Sendor (2002) Although several student-expres- sion cases have been decided by the U.S. Supreme Court, to date, no dress- code case has been heard by the High Court. In the area of student expression generally, however, the recent trend has been toward ?reducing the rights of stu- dents and expanding the discretion of school authorities? (DeMitchell, Fossey, and Cobb 2000). When school officials begin to delve into the area of student dress, they invariably encounter two basic is- sues that may be on a collision course: maintaining a safe and effective edu- cational environment and respecting students? constitutional rights. A re- view of several court decisions in the area of student expression and dress may be useful in raising awareness of issues that should be considered before any policy changes are made. Four Important Cases 1. Tinker v. Des Moines Independent School District Tinker v. Des Moines Independent School District as a landmark case concerning student expression litigated by the U.S. Supreme Court in 1969. Before Tinker, students were not nec- essarily assumed to possess basic con- stitutional rights in the school setting. The assumption was that public-school personnel possessed ?parental preroga- tives? and were entitled to limit stu- dents? rights as they saw fit (LaMorte 1999). In Tinker, the court clearly pro- claimed that students do not ?shed their constitutional rights to freedom of speech or expression at the school- house gate.? At issue in Tinker v. Des Moines Independent School District was whether students had the right to wear black armbands to school as a state- ment of protest against U.S. policy in Vietnam. The court concluded that stu- dent expression is protected unless it could be shown that a particular behav- ior would ?materially and substantially interfere with the requirements of ap- propriate discipline in the operation of the school? or ?collide with the rights of others? (DeMitchell and others 2000). In Tinker, the court upheld stu- dents? right to expression of a social, political, or economic nature, yet it also acknowledged the right of school ad- ministrators to set rules and establish behavioral guidelines for students. In addition, justices explicitly stated that the case did not pertain to the issue of student dress or appearance: The problem posed by the present case does not relate to regulation of the length of skirts or the type of cloth- ing, to hairstyle, or deportment.... Our problem involves direct, primary First Amendment rights akin to ?pure speech.? (DeMitchell and others 2000) In the wake of Tinker, students be- came increasingly confident concern- ing their newfound rights and began stretching their constitutionally pro- tected wings. With Tinker as a back- drop, throughout the 1970s and the first half of the 1980s ?active and lively litigation? ensued in the area of student expression. According to LaMorte, the cases decided during this period did little to dispel fears that the Tinker court had bestowed upon students un- bridled license to behave as they pleased. Several federal courts, relying on the Tinker decision, upheld forms of 12 ERIC Clearinghouse on Educational Management University of Oregon Policy Report Factors Affecting Dress-Code Challenges According to Mary Julia Kuhn, writing in Journal of Law and Educa- tion, legal battles over school dress codes are endemic. The outcome of these battles often depends on five key factors: How the issue is characterized. What specific words are used in the dress code. The geographical area of the conflict. The liberal or conservative trends of the U.S. Supreme Court, combined with the social and political climate of the country. The level of judicial activism of the court. SOURCE: Adapted from Kuhn (1996) VIEWPOINT It is very important for our public schools to respect the variety of different beliefs. When a school policy, which has nothing to do with an important education function, is allowed to override a child?s religion, then basically the child is being denied an education.? ? Deborah Ross, executive director, North Carolina American Civil Liberties Union student expression that many parents and school authorities considered inap- propriate. (LaMorte 1999) During the latter part of the 1980s, however, the pendulum began to shift. Supreme Court rulings in Bethel School District No. 403 v. Fraser and Hazel- wood School District v. Kuhlmeier, in particular, expanded school adminis- trators? rights, giving them greater lati- tude in regulating student expression. 2. Bethel School District No. 403 v. Fraser In 1986, the U.S. Supreme Court decided another case that would have a significant impact on students? rights of expression in the school setting. In Bethel School District No. 403 v. Fraser, t reversed a lower court ruling and upheld the right of school officials to ?sanction a high school stu- dent for using lewd, vulgar, or offen- sive sexual metaphors during a politi- cal speech at a school assembly? (DeMitchell and others 2000). In its decision, the court noted that part of the role of public education is to develop in students ?the habits and manners of civility.? The court stated that ?the undoubted freedom to advo- cate unpopular and controversial views in schools and classrooms must be bal- anced against the society?s counter- vailing interest in teaching students the boundaries of socially appropriate be- havior.? Whereas Tinker ruled that student expression could be prohibited only when it collided with the rights of oth- ers, Bethel v. Fraser ?eased the stan- dard in that the sensibilities of others must be taken into account when view- ing the propriety of student speech.? The court held that ?the determination of what manner of speech in the class- room or in a school assembly is inap- propriate properly rests with the school board.? 3. Hazelwood School District v. Kuhlmeier In 1988, the principal of Hazel- wood East High School outside St. Louis, Missouri, removed from the stu- dent newspaper two student-written articles that he found objectionable. The articles on teen pregnancy and the impact of divorce on students were in a special teen-issue section of the newspaper. Members of the student staff sued. The U.S District Court for the East- ern District of Missouri held that stu- dents? First Amendment rights were not violated. The students appealed to the U.S. Eighth Circuit Court of Appeals, which reversed the district court?s de- cision, taking its cue from the Tinker v. Des Moines decision. On appeal to the Supreme Court, a majority of jus- tices reversed the Court of Appeals decision, applying a ?forum analysis? and holding that the school as a ?closed forum? had the right to exercise rea- sonable control of the school-spon- sored newspaper produced as part of a class. 4. Canady v. Bossier Parish School Board Canady v. Bossier Parish School Board, ning the constitu- tionality of student uniforms, was ini- tially heard in district court and subse- quently appealed to the Fifth Circuit Court of Appeals. In 1997, the Louisi- ana Legislature passed a law allowing local school boards to mandate student uniforms. As a result, during the 1998- 99 school year, the Bossier Parish School Board implemented a manda- tory uniform policy on a trial basis in sixteen of its thirty-four schools. The goal was to determine whether uni- forms had a positive effect on behav- ior and academic performance. According to district personnel, test scores improved and disciplinary problems such as fights declined fol- lowing implementation of the trial uni- form policy. The following year the policy was expanded to include all schools and all grade levels. The policy did not include an opt-out provision. Subsequently, some parents in the affected schools challenged the uni- form requirement, ?arguing that uni- forms stifle individual expression, do not improve the learning environment, are expensive, and violate religious rights? (National School Boards Asso- ciation 2001). When a district court ? Policy Report ERIC Clearinghouse on Educational Management University of Oregon 13 VIEWPOINT The choice to wear clothing as a symbol of an opinion or cause is undoubtedly protected under the First Amendment if the message is likely to be understood by those intended to view it.? ?Robert M. Parker, judge, Fifth U.S. Circuit Court of Appeals PR heard the case, it found the policy did not violate students? free-speech rights. When the decision was appealed, the Fifth Circuit Court of Appeals upheld the lower court. In writing the court?s opinion, Judge Robert M. Parker acknowledged that students have a constitutional right to free expression under the First and Fourteenth Amendments, and a person?s choice of clothing can be a constitutionally protected form of ex- pression. However, Judge Parker ex- plained, the right to free speech is not absolute. Courts have concluded in many cases that sometimes school boards? regulation of student behavior outweighs individual students? right to free speech. The court applied a four-step test to determine constitutionality. Under that test, a uniform policy passes constitutional muster if The school board has the power to make such a policy. The policy promotes a sub- stantial interest of the board. The board does not adopt the policy to censor student expres- sion. The policy?s ?incidental? re- strictions on student expression are not greater than necessary to promote the board?s interest. (Dowling-Sendor 2002) Dress Codes and School-Uniform Policies, State by State No state to date has legislatively mandated the wearing of school uniforms. Following is a roundup of legislation collected from responses to que- ries submitted to state department of education personnel and/or gleaned from each state?s website. If your state is not listed, its omission does not necessarily mean it has no legislation pertaining to student dress. Con- sult your local authorities. For more complete information about legislation in your state, contact offi- cials at your state?s education department. You can begin your search at www.50states.com. ERIC/CEM personnel polled officials in all fifty states for information on statutes regarding dress codes and uniforms. We also searched the statutes posted on each state?s website. Key features of the statutes we located are summarized in the following list. Although most dress codes and uniform policies are developed at the dis- trict or school level, twenty-eight states and the District of Columbia have en- acted laws?with varying degrees of detail and interpretation?that address school dress. Some state statutes affect only dress codes with no mention of uniforms; others address dress codes and uniform policies separately; others include uniforms within dress codes. Arizona Uniforms: District boards have the dis- cretionary power to require students to wear uniforms. Arkansas Dress Codes: District boards may, if they choose, form a parent/student advisory committee to determine whether a student dress code should be enacted. If so, the is- sue will be brought to the voters in the dis- trict for approval. California Dress Codes: Districts may establish a reasonable dress code, as part of their school safety plan, that prohibits pupils from wearing gang-related apparel. Uniforms: Districts may also require stu- dents to wear uniforms. Parents must be in- formed six months before the uniform policy takes effect. The policy must provide an opt-out clause and ensure that no student will undergo sanctions for not participat- ing. Colorado Dress Codes: Local boards may establish dress codes that require minimum standards of dress. Uniforms: Local boards may require stu- dents to wear school uniforms. Connecticut Uniforms: Local or regional boards may adopt a school-uniform policy. Delaware Dress Codes/Uniforms: District boards have the authority to create and enforce a dress-code program, which may include school uniforms. The program must ensure that uniforms are offered at an affordable price and include a plan to assist economi- cally disadvantaged students in obtaining uni- forms. District of Columbia Dress Codes/Uniforms: Each superinten- dent?s long-term reform plan must describe how the district will develop and implement a dress code, which may include uniforms. The dress code must include a prohibition of gang membership symbols and take into ac- count the relative costs of any such code for each student. Florida Dress Codes/Uniforms: School boards may require uniforms to be worn by students or impose other dress-related requirements if the boards find those requirements are necessary for the safety and welfare of students or school personnel. ? 14 ERIC Clearinghouse on Educational Management University of Oregon Policy Report Minnesota Uniforms: Under the statute governing authorized fees, the law says that if a school board adopts a uniform policy, students are required to purchase a school uniform. The board must pro- mote student, staff, parent, and community involvement in the program and ?account for the fi- nancial ability of students to pur- chase uniforms.? Missouri Dress Codes/Uniforms: Public school districts may determine whether a dress-code policy that requires students to wear a school uniform is appropriate for any school within the district. If so, the district may determine the style of the uniform. Nevada Dress Codes: School boards may adopt a dress code for teach- ers and staff within their dis- tricts. Uniforms: Boards may, ?in consultation with the schools within the district, parents and legal guardians of pupils who are enrolled in the district, and as- sociations and organizations rep- resenting licensed educational personnel within the district,? es- tablish a uniform policy. The policy must include a description of the uniform and specify which students must wear a uniform and when they must wear it. Boards must help parents or guardians who request financial assistance to purchase uniforms. New Hampshire Dress Codes: The law states: ?While a school board does have power to adopt reasonable re- strictions on dress as part of its educational policy and as an edu- cational device, the school board?s power must be limited to that required by its function of administering public education.? New Jersey Dress Codes/Uniforms: On the request of the principal, staff, and parents of students at a school, the local board may en- act a dress code that includes uniforms, provided the board finds the policy will improve the ?school learning environment.? The policy, when adopted after a public hearing, must give parents three months? notice and include a provision to assist economi- cally disadvantaged families. The principal, staff, and parents of students at individual schools will choose the uniform. The board may choose to add a fam- ily opt-out clause, and students who opt out cannot be sanctioned academically or otherwise. New York Dress Codes: Currently, local school boards may set provisions regarding student dress deemed ?appropriate and acceptable? and dress deemed ?unacceptable and inappropriate? on school prop- erty. A bill introduced in the state assembly in 2002, currently held for consideration, directs the commissioner of education to adopt rules requiring all school districts to study and adopt dress codes. North Carolina Uniforms: The state board of education may authorize school- uniform pilot programs in as many as five local districts. The state board will develop guide- lines for local boards to use when establishing uniform policies. The guidelines will recommend ways to involve parents and the community in the pilot programs, protect students? rights, and con- sider the ability of students to purchase the uniforms. No state funds will be used for uniforms. Ohio Dress Codes/Uniforms: Local boards may adopt dress codes or uniform policies under the con- ditions that principals, staff, and parents are given the opportunity to offer suggestions and com- ments; parents receive six months? notice before a specific uniform is required; a plan for helping low-income families ob- tain uniforms is part of the policy; and students who partici- pate in a nationally recognized youth organization are allowed to wear that organization?s uniform on days that the organization has a scheduled activity. Oregon Uniforms: Local school boards in Oregon have the authority to impose uniform policies without state legislation. Oklahoma Dress Codes/Uniforms: Local boards have the option of adopt- ing a dress code that includes school uniforms. Pennsylvania Dress Codes/Uniforms: Local boards have the option of adopt- ing a dress code that includes school uniforms. Dress codes Illinois Dress Codes/Uniforms: When ?necessary to maintain the or- derly process of a school func- tion or prevent endangerment of student health or safety,? school boards may establish uniform policies for all or some schools under their jurisdiction. The policy must allow a grace period, during which students who have not purchased uniforms or dress- code compliant clothes will not be disciplined. The policy must also make provisions to accom- modate economically disadvan- taged students and allow for pa- rental opt-out on religious grounds. Indiana Dress Codes: The governing body of a school corporation must establish written discipline rules, which may include dress codes. Iowa Dress Codes: District boards may establish a dress code districtwide, or individual schools may do so, that bans gang-related or other specified apparel if the board determines that the code is necessary for the health and safety of students and staff or for the appropriate dis- cipline and operation of the school. Kansas Dress Codes: In the section of the law that details grounds for which a student may be sus- pended or expelled, school boards have the authority to es- tablish dress codes. Louisiana Dress Codes/Uniforms: Local school boards may establish a dress code that includes uni- forms. The policy must contain an opt-out provision and require no expenditure of school or school board funds. Maryland Uniforms: The school board has the authority to implement a uniform policy in the public schools in Prince George?s County. Massachusetts Dress Codes: By law, school officials may not ?abridge the rights of students as to personal dress and appearance? by impos- ing dress codes unless personal dress ?violates reasonable stan- dards of health, safety, and cleanliness.? and uniform policies may apply throughout a district or only to individual schools. Tennessee Uniforms: The state board of education will create guidelines for local boards that choose to adopt a uniform policy. The guidelines will require that uni- forms be ?simple, appropriate, readily available, and inexpen- sive.? Texas Uniforms: Each district board may adopt a school uniform policy. The policy must indicate where monies will come from for purchasing uniforms for eco- nomically disadvantaged fami- lies, provide an opt-out provi- sion, and go into effect ninety days after the board adopts the rules. Utah Uniforms: Local boards may implement school-uniform poli- cies after holding a public hear- ing. If 20 percent of parents of students sign a petition objecting to the policy and the petition is presented to the local board within 30 days of the adoption of the policy, an election must be held to consider revocation of the policy. Virginia Uniforms: The state board of education will develop guide- lines for local boards to use when establishing uniform policies. The guidelines will suggest ways to involve parents and the com- munity, protect students? rights, and consider the ability of stu- dents to purchase the uniforms. No state funds will be used for uniforms. Washington Dress Codes/Uniforms: School district boards may estab- lish dress codes that prohibit gang-related apparel and man- date uniforms. They may not pro- hibit students from wearing clothing in observance of their religion. If students are required to wear uniforms, school districts ?shall accommodate students so that the uniform requirement is not an unfair barrier to school at- tendance and participation.? Stu- dents who participate in a nation- ally recognized youth organiza- tion must be allowed to wear that organization?s uniform on days that the organization has a sched- uled activity. PRPRPRPRPR Policy Report ERIC Clearinghouse on Educational Management University of Oregon 15 Guiding Principles When Drafting a Dress-Code Policy Fortunately for policymakers considering a dress code or a school- uniform policy, others have already done the fitting and created the patterns. Just like tailored clothes, tailored dress codes fit better and are more comfortable and stylish. Each school is unique, and dress-related concerns vary from school to school, district to district. One-size-fits-all dress codes solve nothing and usually end up annoying almost everyone. Guidelines for Policymakers I Nathan Essex (2000) offers the fol- lowing ten guidelines to assist policymakers in developing reasonable dress-code and school-uniform poli- cies. Above all else, it is essential to in- volve parents, teachers, community leaders, and students. As with most school-based issues, involving all con- stituents is wise. If a committee con- sisting of all segments of the commu- nity is established and policy devel- oped around a core of consensus, fewer objections will likely be raised later on. 1.Make certain that the policy does not restrict religious expression. Various forms of religious expression such as wearing a head covering or a cross should be respected as long as stu- dents? expression of their religious convictions does not infringe upon the rights of others. 2.Provide as much flexibility as pos- sible. If student uniforms are adopted, schools must decide Although one dress-code policy will not fit all schools, Christopher Gilbert offers some general principles applicable across schools that can as- sist administrators in formulating their own policies: School officials must adopt the Tinker standard. Experience shows that in most dress-code disputes, the courts are likely to find in favor of students unless facts exist that would reasonably lead school officials to anticipate considerable disruption of or interference with normal school activities. School officials may prohibit ob- scene, lewd, or vulgar clothing, but they must be careful when drafting policies that discriminate against speech on the basis of content. Administrators must be able to clearly explain why the dress-code policy was implemented and what prompted the specifics of the code. Although school officials frequently create dress codes to combat what they perceive as the presence of gangs on campus, they must not rely on vague antigang rhetoric to justify a dress code when the evidence does not bear out a threat from a gang presence. Restrictions aimed at gang-related attire must be drawn carefully to avoid being declared void because of vagueness. Students do not have a constitutional right to wear baggy pants. The courts appear more inclined to uphold rules aimed at elementary students than they do rules aimed at high-school students. The broader the ban, the more likely the courts are to uphold it. The fact that such broad categorical bans are usually passed before any problems arise demonstrates that the school was not singling out any particular students. 000000000000000 SOURCE: Adapted from Gilbert (1999) whether the policy is mandatory or optional. In schools where incidents of violence or gang activity are com- mon, a mandatory uniform policy may be defensible. Otherwise, the policy should include an opt-out pro- vision. 3.Protect students? rights to freedom of expression lowed to wear symbols that express their political or personal views on issues as long as their expression does not create a ?material and sub- stantial disruption to the educational process.? However, since the courts agreed in Bethel School District No. 403 v. Fraser t of the school?s role is to teach civility and instill stu- dents with socially accepted values, schools are within their rights to adopt dress codes that prohibit stu- dents from wearing clothing that dis- plays vulgar, pornographic, or racist messages; advocates discrimination or violence; or promotes the use of tobacco, alcohol, or other drugs. 4.Provide assistance for economically disadvantaged students ficials should ensure that acquiring uniforms or complying with dress- code requirements will not place an undue hardship on low-income fami- lies. Some schools arrange for uni- form manufacturers to provide vouchers for students whose families cannot afford them; others raise funds or secure a grant to help; and others have instituted hand-me-down or swap programs. 5.Implement a pilot program where fea- sible 16 ERIC Clearinghouse on Educational Management University of Oregon Policy Report Sample Dress Code Here, drawn from a variety of sources, is text of a sample dress code. policy on a limited trial basis such as in a single grade or a single school within a district may reveal unfore- seen problems, provide a more accu- rate indication of the level of support, pave the way for a gradual phase-in, or even demonstrate that a change in policy is unnecessary. A pilot pro- gram also provides school officials with an opportunity to further edu- cate parents and students about ex- actly how the new policy will be put into effect. 6. Be prepared to enforce the dress code tors must ensure that any student- uniform policy or restrictive dress code is applied con- sistently and fairly. Consequences for failure to adhere to the adopted policy should be consis- tent as well. If a uni- form policy has an opt-out provision and is voluntary rather than manda- tory, students should not be harassed, ostracized, or penalized for choos- ing not to participate. 7.Implement a dress code as a compo- nent of a school-safety program. Ob- viously, issues that create unsafe schools will not magically vanish simply because school officials de- cide that students must change what they wear to school. A change in dress codes should be viewed as one element in an overall safety program. VIEWPOINT Elementary schools are a lot easier to implement uniforms in than in the older grades. Seventh and eighth graders are a lot more resistant.? ?Ray Rivera, principal, Eastwood Knolls School, El Paso, Texas 1. You have a right to choose your own style of dress and personal appearance, as long as it does not interfere with the educational pro- cess or academic decorum or endanger student health and safety or cause undue maintenance problems for the school. 2. You are encouraged to ?dress for success? as ma- ture young adults and to make clothing choices that are consistent with our school?s mission and the learning and social environ- ment that the administration strives to provide for all stu- dents. 3. A dress code will be imple- mented, beginning January 2003, for the following rea- sons: a. To ensure the safety, health, and well-being of all students and staff. b. To further the school?s mission: to provide a posi- tive learning environment that prepares students for the world of work, family, and personal ad- vancement and fulfill- ment. c. To ensure that clothing and personal appearance do not distract others from the pursuit of their academic goals. d. To discourage the en- dorsement of alcohol, to- bacco, and other drugs, and disruptive behaviors. e. To respect the personal beliefs and religious rights and freedoms of all students and staff. 4. Student dress is a concern between the student and parents. Dress is a reflec- tion of how one feels about himself/herself. Students must dress appropriately. In order to provide an at- mosphere conducive to learning, all students will follow the regulations be- low: a. Students may not wear clothing with writing, slo- gans, pictures, or sym- bols that depict alcohol, tobacco, or drugs (or their manufacturers). b. Students may not wear clothing with writing, slo- gans, pictures, or sym- bols that depict obsceni- VIEWPOINT If it means that teenagers will stop killing each other over designer jackets, then our public schools should be allowed to require the students to wear school uniforms.? ?President William Clinton, State of the Union Address, January 23, 1996 ? ? 8.Be sure the policy passes legal re- view. Before any new policy is adopted, a draft needs to be carefully examined by the school?s or district?s attorneys to make certain it is clear, appropriate, and able to withstand any potential legal challenges. If re- Policy Report ERIC Clearinghouse on Educational Management University of Oregon 17 Guidelines for Policymakers II James Van Patten and Jerry Siegrist, following their research, sug- gest that a school-uniform policy ide- ally should: Set reasonable dress rules. Allow alternative means of expres- sion. Give students an opportunity to transfer to other schools. Set up a specific discipline procedure and phase-in period to give students time to adjust to the policy. Consider a voluntary policy or an opt-out provision. Assist families who cannot afford uniforms. Allow dress-down days. 000000000000000 SOURCE: Adapted from Van Patten and Siegrist (2000) ties, vulgarity, racism, mu- tilation of humans or ani- mals, sex, or gang affilia- tion. c. Students may not wear im- modest clothing, which in- cludes clothing that ex- poses undergarments or inappropriately exposes the body (bare midriffs are discouraged). d. Students may not wear beach or swimming attire, or clothing generally con- sidered sleeping attire. e. Students may not wear pants in a sagging manner (below the hips). Pants shall not be ripped nor ex- tend below the heel of the shoe. f. Students may not wear or carry hats, caps, head wraps, scarves, ban- danas, or other head ap- parel during the school day, unless that head ap- parel is part of a school?s athletic team?s uniform or part of a student?s cus- tomary religious attire. g. Students may not wear chains on wallets or belts, or carry cell phones, as these may pose a danger. h. Students shall wear shoes at all times. i. Students may not wear sunglasses in class. 5. Violations of the dress code will result in the fol- lowing: a. First violation: a verbal warning. b. Second violation: a writ- ten warning requiring a reply from student?s par- ent or guardian. c. Third violation: student will be required to return home and change into appropriate attire. d. Fourth and subsequent violations: suspension, the duration to be deter- mined by the severity of the infraction and the student?s willingness to cooperate with school officials and adhere to the standards of the dress code. 6. Violations of this dress code shall be treated as disruptive behavior in vio- lation of the Student Code of Conduct. How- ever, dress-code viola- tions shall not carry over on the student?s disci- pline record to subse- quent years. This dress code shall apply to stu- dents at all times when they attend school or any school-sponsored event. The company that we purchase our uniforms from provides coupons for children who are unable to afford uniforms. Plus, our community is so close-knit that our parents have an informal clothing bank. We don?t have enough room at the school to house one, but the parents communicate with each other, and no one is left out.? ?Marie Goodrum, principal, Pinewood Elementary, North Lauderdale, Florida VIEWPOINT ? visions in the policy are needed, a fi- nal review should occur after the changes have been incorporated. 9.Be prepared to review and revise the policy as the need arises. If issues or conditions arise that are not directly addressed by the policy, a committee consisting of teachers, parents, stu- dents, and community leaders should meet to decide whether modifica- tions are warranted. The committee should also engage in periodical as- sessments of the policy to deter- mine if it is meeting its intended purpose. 000000000000000 SOURCE: Adapted from Essex (2001) 18 ERIC Clearinghouse on Educational Management University of Oregon Policy Report Conclusion When they are justified by a school?s circumstances, wisely conceived in collaboration with the community, and coupled with other appropriate interventions, dress codes and school-uniform policies may positively in- fluence school climate, student behavior, and academic success. How- ever, it is critical to keep such policies in proper perspective and avoid overestimating or exaggerating their potential benefits. Forest (1997) contends that instituting student uniforms to stop violence is akin to applying ?a bandage on an enormous wound, instead of attempting to find ways of truly dealing with the bleeding.? Lane, Richardson, and Van Berkum (1996) warn that ?any belief that schools can control society?s prob- lems by regulating what students wear or how they wear it, is hopeful at best, and hopelessly simplistic at worst.? Above all, according to research- ers and experienced administrators, any dress code or uniform policy must be justifiable, reasonable, and man- ageable. The challenge for school of- ficials is to develop dress codes and uniform policies that respond to the needs of their district or school with- out being unduly restrictive. Forcing dress codes or uniforms without the cooperation of the whole school commu- nity only invites problems. Yet, in spite of the best intentions and input of school board members, par- ents, and even students, the onus for implementing and enforcing a dress code or uniform policy ultimately falls on principals and teachers. Principals and teachers must continually work to balance school safety and academic achieve- ment with students? rights and individualism, not an easy task. And adding the job of ?fashion police? to teachers? already heavy workloads is bound to put a strain on individual teachers, schools, and even districts. With more empirical research will come more enlightened dress-code poli- cies; with more successes will come more cooperation. And in time, who knows? Dress codes and uniforms may become de rigueur, or they may become out- moded and fade away like last year?s fashions. ?Dress code disputes are alive and well, and are not likely to disappear any time soon. . . . Draft- ing a successful dress code is both an art and a science. . . . The keys to a successful dress code policy are common sense, the ability to compromise, and the desire of all parties involved to work through their differences.? ?Gilbert (1999) PR PR Guidelines for Policymakers III Elizabeth Garcia and Max Madrid suggest that schools adhere to the fol- lowing guidelines when creating dress codes or school-uniform policies: Policy should focus on pedagogical and school-safety concerns. Determine whether parents support a school dress code. Seek parents? input on design of uniforms. Consider including justifications in dress-code policy, such as decreas- ing criminal activity, curbing gang activity, monitoring intruders. Determine whether to have a man- datory or voluntary uniform policy. Allow some variety and flexibility in the dress code or uniform policy. Be able to justify the action by dem- onstrating the link between a certain kind of dress and disruptive behav- ior. When proscribing general types of clothing, don?t refer to specific brands of clothing. Provide students with ample notice of the dress code or uniform policy. Protect students? other rights of ex- pression. Consider financial assistance to stu- dents unable to afford school uni- forms. Do not require students to wear a particular message on a school uni- form. Make the dress code flexible to ac- commodate students whose religious attire may be inconsistent with the school?s dress code. Uniforms should be gender-neutral. For example, a school should offer the option of a skirt or pants to fe- males. Apply the dress code or uniform policy impartially and consistently. Strive to gather empirical evidence such as a reduction in violent inci- dents and student-discipline reports to establish the effectiveness of a dress code or a uniform policy. Consult the school attorney. Update the dress code on a consis- tent basis. 000000000000000 SOURCE: Adapted from Garcia and Madrid (1999) Policy Report ERIC Clearinghouse on Educational Management University of Oregon 19 Bibliography Many items in this bibliography are indexed in ERIC, the nation- wide information network sponsored by the U.S. Department of Education that is designed to provide ready access to education literature. Each document in the ERIC database has an ?ED? (ERIC Document) designation and a unique six-digit document-specific number. Each journal article in the database has an ?EJ? (ERIC Journal) designation and a six-digit number that identifies that specific article. Most of the documents with an ?ED? prefix can be ordered from the ERIC Document Reproduction Service (EDRS) in elec- tronic (Adobe PDF), paper, or microfiche format. (Items with an ?EJ? designation cannot be ordered through EDRS; patrons must access the journal in which the article originally appeared.) Or- ders can be placed over the EDRS website or via phone, fax, or mail. Specify the ED number, type of reproduction desired, and number of copies. To contact EDRS by phone, call 1-800-443- 3742. To place an order from the EDRS website, go to http:// www.edrs.com menting in a At-Risk School.? Paper presented at Education Law Association 47th Annual Conference, Al- buquerque, New Mexico, November 15-17, 2001. ED 461 181. DeMitchell, Todd A.; Richard Fossey; and Casey Cobb. ?Dress Codes in the Public Schools: Principals, Poli- cies, and Precepts.? Journal of Law and Education 29, 1 (January 2000): 31-49. EJ 606 474. Dowling-Sendor, Benjamin. ?A Question of Rights vs. Authority.? American School Board Journal 188, 7 (July 2001): 38-39. EJ 630 849. ___________ . ?Disagreeing over Dress: Can Schools Restrict Student Expression because It Conflicts with the Values They Want To In- still?? American School Board Journal 188, 1 (Janu- ary 2001): 16-17, 55. EJ 621 296. ___________ . ?School Uni- forms Redux.? American School Board Journal 189, 3 (March 2002): 38-39, 47. EJ 642 944. Education Commission of the States. ?School Uniforms and Dress Codes: State Policies.? ECS StateNotes, 2001. http://www.ecs.org/ clearinghouse/27/09/ 2709.doc Education Week. ?School Uniforms.? Education Week on the Web Issues Index, 2001. http:// www.edweek. org/context/topics/issue page.cfm?id=38 Elder, Deborah, L. ?Evaluation of School Uniform Policy at John Adams and Truman Middle Schools for Albuquerque Public Schools.? Albuquerque, New Mexico: Albuquerque Public Schools, Depart- ment of Research, Devel- opment, and Accountabil- ity, February 1999. 37 pages. ED 453 580. Essex, Nathan L. ?School Uniforms: Guidelines for Principals.? Principal 80, 3 (January 2001): 38-39. EJ 619 650. Forest, Stephanie. ?Dressed to Drill.? Business Week (September 8, 1997): 40. Garcia, Elizabeth A., and Max J. Madrid. ?Student Dress Codes: Constitutional Requirements and Policy Suggestions.? Albuquerque, New Mexico: Modrall, Sperling, Roehl, Harris, and Sisk, P.A., May 21, 1999. http://www.modrall. com/articles/article_13. html Gehl, Kate. ?Dress Code Exposed: Brookfield East Enforcement Riles Stu- dents.? Milwaukee Journal SentinelOnline. April 29, 2002. http://www.jsonline. com/lifestyle/jump/apr02/ 38008.asp Gilbert, Christopher B. ?We Are What We Wear: Revisiting Student Dress Codes.? Brigham Young University Education and Law Journal (Summer 1999): 3-19.http:/ /www.law2.byu.edu/jel/ v1999_2.htm Harris Bowman, Darcia, and Kevin Bushweller. ?Dress Codes Target Risque Styles.? Education Week on the Web 21, 2 (September 12, 2001): 1, 18. Kahl, Kristi. ?Are School Uniforms and Middle School Reform Compat- ible?? The Latest News from Reforming Middle Schools, April 1997. http:// www.middleweb.com/ NEWSuniforms.html King, Keith. ?Should School Uniforms Be Mandated in Elementary Schools?? New Century School Issues Forum: School Uniforms, January 1998. http:// danenet.wicip.org/ncs/ forumuniformseval.htm Kuhn, Mary Julia. ?Student Dress Codes in the Public Schools: Multiple Perspec- tives in the Courts and Schools on the Same Issues.? Journal of Law and Education 25, 1 (Winter 1996): 83-106. EJ 527 561. LaMorte, Michael W. School Law: Cases and Concepts. Sixth Edition. Needham Heights, Massachusetts: Allyn and Bacon, 1999. 439 pages. ED 415 572. Lane, Kenneth E.; Michael D. Richardson; Dennis W. Van Berkum; and Stanley L. Swartz. ?A Dilemma: Dress Codes, Safety, and Dis- crimination.? In The School Safety Handbook: Taking Action for Student and Staff Protection, edited by Kenneth E. Lane; Michael D. Richardson; and Dennis W. Van Berkum. 83-91. Basel, Switzerland: Technomic Publishing Company, 1996. ED 421 746. Learning, Jeremy. ?Public School Dress Code Challenged on Religious Liberty Grounds.? The Freedom Forum, February 1, 1999. http://www.free domforum.org/templates/ document.asp?documentID=8553 Lumsden, Linda. ?Uniforms and Dress-Code Policies.? ERIC Digest Series. No. 148. May 2001. Eugene, Oregon: ERIC Clearing- house on Educational Management, University of Oregon. 2 pages. ED 454 568. Full text available online at http://eric. uoregon.edu Majestic, Ann L., and Tharrington Smith. ?Student Dress Codes in the 1990s.? In Legal Guidelines for Curbing School Violence y Jonathan A. Blumberg; Ruth T. Dowling; Janet L. Horton, Janet; Margaret- Ann F. Howie; Ann L. Majestic; Richard A. Schwartz; Brian C. Shaw; and Bruce W. Smith. Raleigh, North Carolina: National School Boards Association?s Council of School Attorneys, 1995. 141 pages. ED 423 580. Marchant, Valerie. ?Dress for Success.? TIME 154, 11 (September 13, 1999). http:/ /www.time.com/time/ archive/preview/0,10987, 1101990913-30497,00.html Michigan State University Ex- tension, Children, Youth, and Families Program. ?Ex- amining the School Uniform Debate ? Infringing on Your Kids? Rights or Focus- ing Your Child?s Attention on Academics.? School Uni- forms Debate. East Lansing, Michigan: Author. http:// Authors Unknown. ?A Modest List of Debating Points About Mandatory Public School Uniforms.? Site for Opposition to Mandatory Public School Uniforms, n.d. http://school uniforms- not.org/debates.html BlueSuitMom.com. ?Public School Dress Codes Grow- ing More Popular.? August 2000. http://www.bluesuit mom.com/family/education/ schooluniforms.html Brunsma, David L., and Kerry A. Rockquemon. ?The Ef- fects of Student Uniforms on Attendance, Behavior Problems, Substance Use, and Academic Achieve- ment.? The Journal of Edu- cational Research 92, 1 (September/October 1998): 53-62. EJ 576 443. Clarksville-Montgomery County School System. ?Dress Code Update.? Sep- tember 26, 2001.http:// admin.cmcss.net/Dress Code/dresscode.html CNN.com. ?Nadine Strossen: Why the ACLU Opposes School Dress Codes.? Tele- phone interview, August 28, 2001a. http://www.cnn.com/ 2001/COMMUNITY/08/28/ strossen.cnna/ ___________ . ?Principal John Brucato: Why Our School Uses a Dress Code.? Tele- phone interview, August 28, 2001b. http://www.cnn.com/ 2001/COMMUNITY/08/28/ brucato.cnna/index.html Coles, Adrienne. ?N.Y.C. Joins Growing List of Districts Dressing the Same.? Educa- tion Week on the Web 19, 13 (November 24, 1999): 6. http://www.edweek.org/ew/ newstory.cfm?slug=13dress.h19 Daugherty, Richard. ?School Uniforms: Can Voluntary Programs Work? Experi- 20 ERIC Clearinghouse on Educational Management University of Oregon Policy Report Clearinghouse on Educational Management 5207 University of Oregon Eugene, Oregon 97403-5207 (800) 438-8841 UNIVERSITY OF OREGON www.msue.msu.edu/msue/ programs/cyf/public_html/ cindy/Revisedrevoflit.htm Morris, Bruce, and Donna Wells (Eds.). ?Dress Codes and Uniforms.? Issue Briefing. Richmond, Virginia: Vir- ginia Commonwealth Edu- cational Policy Institute, 2000. http://www.ecs.org/ ecsmain.asp?page=/search/ default.asp National Association of El- ementary School Principals. ?School Uniforms Why & How.? Principal Online, 2001. http://www.naesp. org./misc/uniforms.htm ___________ . ?Survey of School Principal Reports Positive Effects of School Uniforms.? News Release, July 24, 2000. http://www. naesp.org/comm/prss7-24- 00.htm National School Board Associa- tion. ?Philadelphia Ap- proves School Uniforms.? School Board News (May 16, 2000). http:// www.nsba.org/sbn/00-may/ 051600-3.htm Northrop, John. ?Dress Codes and Social Chaos.? Educa- tion Week 21, 18 (January 16, 2002): 36. Pate Shamburger, Sharon. ?The Influence of a Mandatory School Uniform Policy.? Pa- per presented at the Annual Meeting of the Association for Career and Technical Education, Orlando, Florida, December 12-15, 1999. 13 pages. ED 458 695. Pedzich, Joan. ?Student Dress Codes in Public Schools: A Selective Annotated Bib- liography.? Law Library Journal 57. Point Pleasant Borough High School. ?Point Pleasant Bor- ough High School Dress Code.? Point Pleasant, New Jersey. http://www.point pleasant.k12.nj.ushighschool/ Dress%20Code.htm Siegel, Loren. ?Point of View: School Uniforms.? Ameri- can Civil Liberties Union, 1996. http://archive.aclu. org/congress/uniform.html Simonson, Mary Ellen. School Uniforms: A Blueprint for Legal Challenges.? Inquiry and Analysis (March 1998): 1-7. ED 426 488. Smolkin, Rachel. ?Dress Codes in a Comeback.? Scrips Howard News Service Edu- cation, 1999. http://www. naplesnews.com/special/ school99/d323415a.htm Student Press Law Center. ?Hazelwood School District v. Kuhlmeir.?SPLC Law Li- brary Cases, n.d. http:// www.splc.org/law_library. asp?id=1 Thomas, Karen. ?High Schools to Teens: Put Some Clothes On.? USA Today (August 30, 2001): 1-2D. http://pqasb. pqarchiver.com/USAToday/ U.S. Department of Education. Manual on School Uni- forms. ashington, D.C.: Author, 1996. 9 pages. ED 387 947. http://www.ed.gov/ Van Patten, James, and Jerry Siegrist. ?Developing a Common Faith and Ethic for School Safety.? Paper pre- sented at the Annual Meet- ing of the American Educa- tional Research Association, New Orleans, Louisiana, April 24-28, 2000. 15 pages. ED 446 358. Warner, R. Matthew. ?The Problems with School Uniforms.? Legalis (Fall 1997). http://www.wabash. edu/bop/legalis/issues/ 1997/Fall/uniforms.html Westside High School. ?The Westside Code of Conduct.? Omaha, Nebraska: Author, September 13, 2001. http:// whs.westside66.org/WHS/ 66/aboutwhs/code.html White, Kerry A. ?Do School Uniforms Fit?? School Administrator (February 2000): 36-40. EJ 599 101. Wills, Paul. ?Should Public Schools Require Students to Wear Uniforms?? 2001. http://www.thefence.com/ article.asp?forumid=113 Wilson II, Richard E. ?The Im- pact of School Uniform Dress Code on Principal Per- ception of School Violence.? 1999. 9 pages. ED 449 546.