The courts will entertain an action to consider the propriety of the suspension or expulsion of a student based on the student's hairstyle. The promulgator of the regulation, be it the principal or the board of education, bears a heavy burden of justification for the rule. The two recognized factors that might sustain a hairstyle regulation are: (1) protection of the health and welfare of the individual student, and (2) the need to prevent disruption that would directly interfere with the educational process. Unless one or both of these factors is present, it is likely that a court will not sustain a regulation of hairstyle or hair length. (Author)