In the case of Hortonville Joint School District No. 1 et al. v. Hortonville Education Association et al., the Supreme Court ruled in favor of a school board that had fired striking teachers, stating that it did not violate their due process rights under the Fourteenth Amendment to do so. The court held that because there was no personal or financial stake involved for any member of the school board, they were able to act as impartial adjudicators in this matter despite being party to an employment contract dispute with these teachers and having previously authorized disciplinary action against them for strike-related activities.

The dissenting opinion in the Hortonville Joint School District No. 1 v. Hortonville Education Association case, written by Justice Marshall and joined by Justices Brennan and Stewart, argued that due process was violated when the school board acted as both employer and adjudicator during a teacher strike dispute. They contended that an impartial decision-maker is essential to fair procedure, especially given the adversarial nature of this labor dispute where personal interests were at stake for board members who had children attending district schools or spouses working there. The majority's reliance on local control over education did not justify ignoring constitutional requirements for due process according to them; they believed it would be more appropriate for an independent third party to resolve such disputes instead of leaving it up to potentially biased parties involved directly in conflict.