The Constitutional Limit of Zero Tolerance in Schools

constitutionality of challenge zero tolerance policies and argue for more robust procedural protections in enforcing them.20 Others realize that simply affording more process amounts to doing more of the same. 21 These scholars rightly look to substantive due process solutions, but propose legal theories that are unsupported by existing precedent and would require courts to rework due process doctrine. 22 Finally, some ignore due process altogether, believing the only important limitation on discipline is the prohibition on discrimination.