The case of Dixon v. Alabama: From civil rights to students’ rights

LEXINGTON, Ky. (Feb. 27, 2023) — “Ask me about Dixon v. Alabama.”

It’s the bold-lettered phrase featured on flyers across the University of Kentucky campus.

The purpose — an introduction to the history of your student bill of rights and a challenge to empower you to learn more.

A landmark case in 1961, Dixon v. Alabama ended the culture of colleges and universities acting in loco parentis (in place of a parent) to discipline or expel students.

Since then, the federal court decision has been cited as the beginning of the revolution for student rights.

The case arose a year earlier, when Alabama State College (a then-segregated Black institution) expelled six students, including the named appellant, St. John Dixon, for unspecified reasons. Many presumed it was a result of their involvement in an organized sit-in during the civil rights movement.

Because of these students’ actions, students at state schools today have due process rights.

Mike Brown (associate director of UK Student Conduct in the Office for Student Success) and Ann Moore (student responsibility coordinator) know the case well. Together, they partnered with UKNow and D’lorah Hughes (associate professor in the Rosenberg College of Law) to participate in the Q&A session below.

UKNow: Dixon v. Alabama was the first time any American court recognized students at a state university have due process protection under the 14th Amendment.

How did this pave the path for students’ rights moving forward? 

Moore: The case and decision was monumental — students’ rights, in general, benefited from the Dixon precedent.

For the first time in history, the decision stated, at a minimum, students should be given: notice with a statement of specific charges against them, access to the report and names of witnesses, an opportunity to be heard (present their defense), and a copy of the report detailing hearing findings and outcomes.

UKNow: Talk about how this case went hand-in-hand with the civil rights movement in the late 1950’s, early 1960’s. 

Moore: First and foremost, scholars point to this case as a source of empowerment for student activists. The litigation emboldened students across the country to engage in the civil rights struggle.

Christopher P. Loss (2014) argues in the second article of this special section that “in loco parentis had a caring, nurturing side.” This was true perhaps everywhere but the segregated South, where in loco parentis melded with Jim Crow policies to strengthen white supremacy ideology. Again, this reference comes from Lee, P. (2014). The Case of Dixon v. Alabama: From Civil Rights to Students’ Rights and Back Again from “Teachers College Record.”

Until Dixon v. Alabama, students were participating in demonstrations but also being dismissed from colleges and universities without notice.

The case led to the overturning of these dismissals, because of the lack of due process. Furthermore, it ensured due process for students who continued to participate in the movement after Dixon v. Alabama. 

UKNow: Legal scholars have cited Dixon as the beginning of a revolution for students’ rights in public higher education — why is it just the beginning? 

Brown: This case truly sets the standard for due process in higher education disciplinary proceedings. The court’s ruling made it clear, students have rights, and institutions could no longer rely on the in loco parentis doctrine. This ruling laid the groundwork for college students to protest on campus in the coming years. 

Hughes: In addition to codifying due process rules as required by Dixon v. Alabama, schools must constantly make sure their procedures are written with clarity and are applied consistently. Vagueness and inconsistency may lead to distrust and concerns about arbitrariness.

UKNow: How did the case shape the Student Code of Conduct that we know and adhere to today? 

Brown: The Code of Student Conduct is based on the principles established by Dixon. v. Alabama. These include: providing notification of a meeting or hearing to address an alleged violation of policy; an informal meeting or formal hearing as an opportunity to be heard and share their side of the incident that occurred; and to be provided with a written outcome based on the facts of the case. Following these guidelines allows for a fairness and equality that didn’t exist before.

UKNow: This case was monumental in 1961, but why is it as equally important today? 

Hughes: Just as was the case in 1961, students today want substantive responses to their concerns from campus administration. We should all seek to engage with our student leaders to understand the challenges they face and how we can work together to continue to expand the legacy of Dixon v. Alabama.

Brown: Dixon v. Alabama, and the progress that followed, is as relevant today as it was in 1961. In fact, in 2022, the Kentucky State Legislature passed the Campus Due Process Protection Act to strengthen due process rights for students across the Commonwealth.

As shown in the 1961 decision, and through this most recent legislation, each and every student has the right to be heard, as well as be provided with the written decision based on fact.

UKNow: The Office of Student Conduct launched an “Ask Me About Dixon v. Alabama” campaign this month. What was the inspiration behind this project? 

Moore: It was — and still is — a landmark case that afforded students the rights they have today. For this to occur during the civil rights movement just makes it all that more impactful. We chose to launch the campaign against the backdrop of Black History Month. We want students, and our entire campus community, to ask questions and explore how due process came to be. The students that came before them had a profound impact, not only on the civil rights movement, but on shaping students’ rights.

UKNow: What do you hope students — and the entire campus community — gain from the campaign? 

Moore: A better understanding of how their rights came to be. One of our goals, in the Office of Student Conduct, is to engage with students more and to provide proactive education about the Code of Student Conduct. This campaign is one of many efforts, and we’re proud to be challenging ourselves to help empower our students.

UKNow: Talk about the Office of Student Conduct and its role in ensuring students are treated equitably? How does the work of the process that was established in 1961 continue today?   

Brown: The Office of Student Conduct is responsible for ensuring students alleged of policy violations are afforded a fair process — in which they can share their side and are made aware of decisions made regarding their disciplinary standard.

This becomes especially important when we are removing a student from an education opportunity. By ensuring these due process rights are present, and that our process is transparent, we live up to our promise of being equitable for all students.

If you want to know more about the Dixon v. Alabama case, stop by the Office of Student Conduct. Anyone who asks about Dixon v. Alabama in the month of February will receive a “Wildly Possible” baseball hat.

You can learn more about the Code of Student Conduct here.