In the Harrah Independent School District v. Martin case of 1978, the U.S Supreme Court ruled in favor of a local school board's policy requiring teachers to sign a contract extension early in the calendar year or risk non-renewal. The plaintiff, Geraldine Martin, was an untenured teacher who refused to agree to such an extension before exploring other potential job opportunities. When her contract was subsequently not renewed by the school district and she failed to find employment elsewhere, she sued on grounds that her due process rights had been violated. However, the court held that since there is no constitutional right for any person to be rehired and because Ms. Martin did not have tenure or a formal expectation of continued employment beyond her one-year term (and thus lacked property interest), there were no due process rights at stake.

In the dissenting opinion for Harrah Independent School District v. Martin, Justice William Rehnquist disagreed with the majority's ruling that a public school district could not require a teacher to sign an employment contract containing a no-marriage clause as a condition of continued employment. He argued that such clauses were not inherently unconstitutional and should be evaluated on their individual merits rather than categorically dismissed. He also contended that it was inappropriate for the court to intervene in local matters like this one, which he believed should be left up to state courts and legislatures instead of being decided at the federal level. Furthermore, he expressed concern about potential negative implications of this decision for other types of contractual restrictions between employers and employees.