Most schools have, or had, a policy to prohibit children from wearing a hat at school. Concerns about hats being used as a sign of gang identification are most frequently cited as the reason behind such policy. After learning that some California schools would not even allow a hat to be worn by a child with a strong genetic susceptibility to skin cancer and a doctor’s note, Mrs. Karen Graham took action. Following the death of her son at an early age from melanoma, Mrs. Graham initiated legislation that resulted in an amendment to the California Education Code as follows