Bethel School Dist. No. 403 v. Fraser

In Bethel School Dist. No. 403 v. Fraser, 478 U.S. 675, 682, 106 S.Ct. 3159, 92 L.Ed.2d 549 (1986), Matthew Fraser was suspended for delivering a speech before a high school assembly in which he employed what this Court called "an elaborate, graphic, and explicit sexual metaphor." Id., at 678, 106 S.Ct. 3159. Analyzing the case under Tinker v. Des Moines Independent Community School Dist., 393 U.S. 503, 506, 89 S.Ct. 733, 21 L.Ed.2d 731 (1969), the District Court and Court of Appeals found no disruption, and therefore no basis for disciplining Fraser. 478 U.S., at 679-680, 106 S.Ct. 3159. The Court reversed, holding that the "School District acted entirely within its permissible authority in imposing sanctions upon Fraser in response to his offensively lewd and indecent speech." Id., at 685, 106 S.Ct. 3159. The mode of analysis employed in Fraser is not entirely clear. The Court was plainly attuned to the content of Fraser's speech, citing the "marked distinction between the political `message' of the armbands in Tinker and the sexual content of Fraser's speech." Id., at 680, 106 S.Ct. 3159. But the Court also reasoned that school boards have the authority to determine "what manner of speech in the classroom or in school assembly is inappropriate." Id., at 683, 106 S.Ct. 3159. Cf. id., at 689, 106 S.Ct. 3159 (Brennan, J., concurring in judgment)