That left Benya's classmates free to wear bright orange, red and striped ties under their gowns at the ceremony Wednesday at the Show Place Arena in Upper Marlboro. One senior girl wore a headscarf and long pants for religious reasons.
"The First Amendment protects religion, and we do everything possible to honor that," O'Malley-Simpson said. "There is nothing that requires us to follow everyone's different cultures."
The courts have ruled that students have limited rights to express themselves at school as long as their behavior is not disruptive. A 1969 Supreme Court case, Tinker v. Des Moines, sided with students who wanted to wear black armbands to school to protest the Vietnam War.
David Rocah, a staff lawyer with the American Civil Liberties Union of Maryland, said there are limits to those rights. Carrying political placards or wearing a clown suit to graduation would presumably be disruptive. The question, he said, is whether a bolo tie under a gown is disruptive.
"There's nothing wrong with wanting graduation to be a formal occasion," he said, "but the idea that everyone should look the same -- they're not all the same."
Rocah called the school's interpretation a "narrow and cramped view of personal autonomy."
Benya grew up hearing stories about his paternal grandmother's father and grandfather, who lived in dismal conditions on a Cherokee reservation in Oklahoma. He attends powwows and has worn an heirloom turquoise and silver bracelet for as long as he can remember.
He favors black clothes and prefers working backstage with lights and sound to performing in plays. He said he wasn't looking to cause a scene.
"It's my way of relating back to my past and showing who I am," he said.