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Law School Case Brief

J.C. v. Beverly Hills Unified Sch. Dist. - 711 F. Supp. 2d 1094 (C.D. Cal. 2010)


Any word spoken in a class, in the lunchroom, or on the campus that deviates from the views of another person may start an argument or cause a disturbance, but the U.S. Constitution says we must take this risk. The substantial disruption inquiry is highly fact-intensive.


Plaintiff student brought suit against defendants, a school district and school administrators, after the student was disciplined for posting a video on YouTube. Plaintiff claimed that the act of the defendants was in violation of the First Amendment because the act occurred outside of school. Both parties moved for summary judgment.


Did defendants violate the First Amendment rights of the plaintiff student when they disciplined him for posting a video on YouTube?




The court held that school administrators had authority to discipline students for off-campus speech if such speech caused a substantial disruption at school. The mere fact that students were overheard discussing the video and that the subject of the video was upset by the conversation did not demonstrate a substantial disruption to school activities. However, the school administrators were under the doctrine of qualified immunity. Specifically, qualified immunity shielded public officials sued in their individual capacities from monetary damages.

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