In response to Professor Sacken, contends that a person's decision to conceive and bear a child is within the constitutionally protected zone of privacy. This would not prohibit a district from dismissing an unwed pregnant teacher, but would require evidence of immorality based on constitutionally acceptable criteria. (MLF)

Disagrees with Professor Donal M. Sacken's contention in Spring 1988 "Journal of Law and Education" that "Eckman" decision resulted in loss of school district autonomy. Agrees with jury that school board's dismissal of unmarried teacher, who became pregnant as a result of rape and chose to bear the child and raise him, was…