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Law School Case Brief

Hazelwood Sch. Dist. v. Kuhlmeier - 484 U.S. 260, 108 S. Ct. 562 (1988)

Rule:

The standard for determining when a school may punish student expression need not also be the standard for determining when a school may refuse to lend its name and resources to the dissemination of student expression. Instead, educators do not offend U.S. Const. amend. I by exercising editorial control over the style and content of student speech in school-sponsored expressive activities so long as their actions are reasonably related to legitimate pedagogical concerns. 

Facts:

Respondent Kuhlmeier and other former high school students who were staff members of a school's newspaper filed suit in federal district court against petitioner Hazelwood School District and school officials alleging that their First Amendment rights were violated when two articles were deleted from the school paper. The articles described students' experiences with pregnancy and discussed the impact of divorce on students at the school. The newspaper was written and edited by a journalism class as part of the school's curriculum. Pursuant to the school's practice, the teacher in charge of the paper submitted page proofs to the school's principal, who objected to the pregnancy story because the pregnant students, although not named, might be identified from the text, and because he believed that the article's references to sexual activity and birth control were inappropriate for some of the younger students. The principal objected to the divorce article because the page proofs identified a student who complained of her father's conduct, and the principal believed that the student's parents should have been given an opportunity to respond to the remarks or to consent to their publication. Believing that there was no time to make necessary changes in the articles if the paper was to be issued before the end of the school year, the principal directed that the pages on which they appeared be withheld from publication even though other, unobjectionable articles were included on such pages. The district court held that no First Amendment violation had occurred. On appeal, the United States Court of Appeals for the Eighth Circuit reversed.

Issue:

Was the principal's decision to exclude articles from the school newspaper violative of the students' First Amendment rights?

Answer:

No.

Conclusion:

The Supreme Court of the United States reversed the appellate court's decision because the Court found that the principal's actions were reasonable. The Court found that public schools did not possess all of the attributes of streets and other traditional public forums. The school had an interest in protecting the identity of the students in a pregnancy article as well as maintaining the integrity of student speech allowed in the school newspaper. Therefore, no violations of U.S. Const. amend. I rights occurred.

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