In Loco Parentis: Curfews & Curlers
Curfew and Curlers
Student Activism in the Early 1960s
By Craig Forrest
Jan Simmons was not amused. After observing women students at breakfast in the Dobbs residence hall group cafeteria wearing short-shorts, hair curlers, and pink bunny-fur slippers, she immediately issued additional rules defining acceptable attire for women in their dormitories. As the new manager of women’s residence halls at the University of Missouri in Columbia, Simmons had the authority to impose her own standards of propriety on the undergraduates in her charge. She justified her expansion of the rules to ban hair curlers, bandanas, scarves, kerchiefs, hairnets, slacks, and shorts in cafeterias and lounges with the admonition that “our personal appearance is as important as our behavior and our speech in conveying to others the kind of people we are.” The women who had to comply with these new regulations were unhappy, but in that September of 1961 it appeared that they had no choice but to obey Simmons’ dictates or suffer the consequences.
At the beginning of the 1960s, the University of Missouri, as well as every other institution of higher learning in the United States including IU (see opposite page), still operated under the legal regime of in loco parentis. This legal term translates literally as “in the place of parents,” and it defined the relationship between administrators and students as one of a legal guardian to a minor. Since at least 1866, courts had recognized the right of colleges to regulate the behavior of students in the same way that parents regulated their own children’s lives. From the founding of the earliest schools in the seventeenth century, American colleges had concerned themselves with the moral guidance of their students as a necessary component of education. In accepting the legal rights granted to them by the courts after the Civil War under in loco parentis to govern student behavior, college administrators were also accepting legal responsibility for their students. By the early 1960s, students in institutions of higher education across the country were subjected to a myriad of rules and regulations as the legal charges of their schools under this in loco parentis regime.
The bedrock principle of in loco parentis as a legal construct was an understanding that college students were minors who had no claim to constitutional rights enjoyed by adult citizens.
At the University of Missouri in 1960 for instance, campus rules reflected this view. In addition to rules that gave administrators the right to censor student speech and regulate the types of organizations allowed on campus, there were rules governing the daily activities of undergraduates. Freshmen of both sexes were forbidden from operating motor vehicles in the city of Columbia, women students were subjected to nightly curfews, and females had to conform to a dress code that required them to wear skirts, blouses, and/or sweaters when out on campus or in town. These rules had been in place at Missouri for years, but during the early 1960s some administrators such as Simmons began to expand them in an attempt to counter the attitudes of a numerically growing student body—a student body comprised of a generation that had begun to openly question the very idea of in loco parentis on campus, and that would work in the coming decade to roll back campus rules.
In April of 1960, the student newspaper at Missouri, The Maneater, reported that administrators had voted to extend the ban on driving from freshmen to sophomores in the upcoming school year without consulting student government before the change. Their stated reason for the extension was poor academic performance by sophomores, and, much like a parent would have done, they contended that eliminating driving privileges would remove a distraction from schoolwork. Instead of acquiescing to the dictates of the administration, however, students fought this rule change through their student government representatives. The Missouri Student’s Association (MSA) sent a letter to the Board of Curators, criticizing the sudden change and lack of student input in the rule-making process. The curators, upon receipt of the letter, suspended the rule change for the coming year and sent the issue back to the administrative board for further review. The administrators dropped the issue, and sophomores were not banned from driving.
In the middle of the brouhaha over sophomore driving privileges, an unnamed former MSA president penned a guest column in The Maneater titled “Students Still Kids Officially.” The author of this column, although without referencing in loco parentis, challenged the administration to give students more of a voice in campus rules that governed their lives. He decried the administrators’ attitude that students were too immature to govern themselves, and suggested that the reason some students acted immaturely was because they were treated as adolescents incapable of self-control. The only remedy for this catch-22 situation was for administrators to acknowledge that college students were indeed mature adults, and include them in the rule-making process. In hindsight, the former student body president’s column appears prescient, because students did in fact take an active role in changing campus rules during the following years.
One of the most dramatic changes in rules at the University of Missouri in the first half of the 1960s was the rolling back, and even the elimination, of women’s curfews. In 1960, all female students were required to be in their residence by a certain time each evening. Freshmen women had to be in by 7:30 Sunday through Thursday night, and by 12:30 am on Friday and Saturday nights. All other females had a curfew of 10:30 on Monday, Tuesday, and Thursday nights, 11:30 on Wednesday and Sunday nights, and 12:30 am on Friday and Saturday. If a student accumulated more than twenty “late minutes” over the course of a semester, she would be “campused,” or grounded to her room between 7 p.m. and 7 a.m. for a number of nights determined by a disciplinary committee. Beginning with the 1962-63 school year, the Association of Women Students (AWS) would successfully push for and succeed in getting many changes to these curfew rules. They were aided in their quest by the Director of Student Affairs for Women, Gladys Pihlblad, whose believed that women students should be given greater freedom on campus. She did not advocate for a complete elimination of hours for females at Missouri in the early 1960s, but she did express the opinion that AWS should be more involved in making the rules for women on campus.
The first change to women’s curfews at Missouri since before World War II came in the fall of 1962. Because of the growing number of female students, all-freshman female dormitories were to be eliminated in 1962-63. AWS proposed that freshmen women be given the same curfew as older females, in part to eliminate the difficulty of having to enforce a separate curfew on students in the same residence hall. The Committee on Student Affairs, made up of administrators including Pihlblad and the Dean of Students, Jack Matthews, approved this rule change. Whether the committee was declaring that eighteen-year-old freshmen women were as mature as twenty-two-year-old seniors, or just trying to streamline curfew enforcement, this constituted an expansion of freedom for women on campus.
By the end of the 1962-63 school year, AWS next began a campaign for “key privileges” for senior women. Key privileges allowed females with senior standing to be issued a key to their residence halls, essentially ending the curfew for those students. Women who wanted to participate in the program were required to get their parents’ permission, and that parental permission would be a first step in releasing the university, in part, from its in loco parentis responsibilities. Negotiations between AWS and administrators went quickly, and the key program went into effect during the spring semester of 1964 for seniors. During the 1964-65 year, AWS lobbied for an extension of key privileges to younger women, and juniors were included in the program during the 1966-67 academic year. Sophomores would be given keys in 1968. In the meantime, AWS was successful during the 1963-64 school year in pushing back the curfew for all women to 11:30 on Sunday through Thursday nights, and to 1 a.m. on Friday and Saturdays. These changes to the curfew rules at Missouri over the course of only five years were the result of student activism—not an activism as well remembered as the higher profile and more publicized activism of the Free Speech and Anti-War Movements, but activism through student government organizations working within the system to effect change.
Simmons’ September, 1961 expansion of the female dress code regulations to residence hall cafeterias and lounges was confronted by a burst of activism as well. In the first week of October, women in the Dobbs group planned a sit-in style demonstration to protest having to dress up for meals. Their plan was for a large number of females to try and get served their dinner while wearing slacks and Bermuda shorts in violation of Simmons’ new rules. Unfortunately for the would-be protesters, Simmons got wind of the plot, and she declared that participants would be punished for “promoting a riot.” The students cancelled their act of civil disobedience, but by working through AWS and the Women’s Residence Hall Association (WRHA) they were able to entirely eliminate the dress code on campus by the end of 1965. Administrators in the first half of the 1960s responded to student pressure and agreed to relinquish their in loco parentis authority, and students continued to push for increased freedom from campus rules through their student government organizations.
By the late 1960s, however, administrators at Missouri and other colleges nationwide became more resistant to the increased demands by students for more freedom on campus. The resulting Free Speech Movement, which began at the University of California Berkeley in 1964, and the desire of students at Missouri to end the “intervisitation” ban, which denied the right of students to visit members of the opposite sex in their personal rooms, found administrators refusing to accept any more loosening of rules that would reduce their in loco parentis rights. In large part, this refusal was borne of the fact that the courts, which had established the in loco parentis regime making administrators responsible for their students as guardians, had yet to release colleges from that legal standing. Court cases in the late 1960s and early 1970s relating to student free speech would explicitly do just that, and only then did universities nationwide relinquish their in loco parentis role.
What the examples at Missouri in the early years of the 1960s show, however, is that even before the well-known Free Speech Movement students on college campuses were actively working to free themselves from in loco parentis controls. These efforts by students are not remembered today nearly as well as the higher-profile campus disturbances of the later 1960s, but they were just as important to students gaining their rights as legal adults as their later efforts. Even in the early 1960s, administrators were signaling their willingness to modify in loco parentis rules, but it was the activism of students that prodded them to do so. The student rights movement, which ultimately resulted in college students being recognized as citizens with constitutionally protected rights, had begun well before the Free Speech Movement appeared on campuses across the country. The better-known Free Speech Movement was actually an extension of these earlier battles for freedom for students on campus, not a spontaneous development with no connection to past events. Modern college students who enjoy their freedoms on campus should be grateful to their predecessors for their rights, and they should be on guard to defend them against current challenges, such as speech codes that restrict free expression, which have been instituted at many schools in the past twenty-five years.
Craig Forrest is a graduate student in History at the University of Missouri.