Law School Case Brief
Pyle v. School Commission of South Hadley (Mass.), et al. - 423 Mass. 283, 667 N.E.2d 869 (1996)
The courts' primary duty is to interpret a statute in accordance with the intent of the legislature. Where the language of a statute is clear and unambiguous, it is conclusive as to legislative intent. Where the ordinary meaning of the statutory terms yields a workable result, the courts need not resort to extrinsic aids of interpretation such as legislative history. The courts accord the words of the statute their ordinary meanings, however, with due regard to the statute's purposes.
The plaintiffs, Jeffrey and Jonathan Pyle, sued the school committee of South Hadley, the interim superintendent of South Hadley schools, and the interim principal of South Hadley High School in the United States District Court for the District of Massachusetts (Federal District Court), claiming that the school's dress code violates their freedom of expression as protected by the First Amendment to the United States Constitution and G. L. c. 71, § 82 (1994 ed.). A Federal District Court judge granted the plaintiffs' motion for an injunction against enforcement of that part of the dress code that prohibits the wearing of apparel that “harasses, intimidates, or demeans an individual or group of individuals because of sex, color, race, religion, handicap, national origin or sexual orientation.” The judge upheld, however, that part of the dress code prohibiting students from wearing clothing that "has comments, pictures, slogans, or designs that are obscene, profane, lewd or vulgar." The judge determined that G. L. c. 71, § 82 has no relevance to the analysis of a school administrator's efforts to curb vulgarity and sexual innuendo. The plaintiffs appealed. The United States Court of Appeals for the First Circuit vacated the ruling on the State law, deferred ruling on the Federal constitutional question, and certified the question of State law to state supreme court.
Do high school students in public schools have the freedom under G. L. c. 71, § 82 to engage in non-school-sponsored expression that may reasonably be considered vulgar, even if it causes no disruption or disorder?
The Supreme Court of Massachusetts held that, under state law, the students had the freedom to engage in non-school sponsored expression that may have been reasonably considered vulgar but caused no disruption. The clear, unambiguous, and mandatory language of G. L. c. 71, § 82 protected the students' rights limited only by the requirement that any expression be non-disruptive within the school. Further, the students' rights under G. L. c. 71, § 82 included expression of views through speech and symbols without limitation. Thus, there was no room in the statute for the Court to construe an exception for arguably vulgar, lewd, or offensive language absent a showing of disruption within the school.
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