Hazelwood School District v. Kuhlmeier

In Hazelwood School District v. Kuhlmeier, 484 U.S. 260 (1988), the Court summarized the basic principles underlying the determination of whether a school district's discipline of a student violates the student's First Amendment rights. In Kuhlmeier, the Court held that the petitioners did not violate the students' constitutional rights when they exercised editorial control over a high school newspaper that was part of the school's curriculum. The district deleted two pages of the newspaper that, in addition to "unobjectionable" articles, contained two "objectionable" articles concerning three student's experiences with pregnancy and the impact of divorce on school students. The Court specifically held that "educators do not offend the First Amendment 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." 484 U.S. at 273. "Students in the public schools do not 'shed their constitutional rights to freedom of speech or expression at the schoolhouse gate.' They cannot be punished merely for expressing their personal views on the school premises--whether 'in the cafeteria, or on the playing field, or on the campus during the authorized hours,'--unless the school authorities have reason to believe that such expression will 'substantially interfere with the work of the school or impinge upon the rights of other students.' "We have nonetheless recognized that the First Amendment rights of students in the public schools 'are not automatically coextensive with the rights of adults in other settings,' and must be 'applied in light of the special characteristics of the school environment.' A school need not tolerate student speech that is inconsistent with its 'basic educational mission,' even though the government could not censor similar speech outside the school." Kuhlmeier, 484 U.S. at 266 .