## Facts

- Thomas Guzick, Jr., a 17-year-old public high school student, wore a pin-on button reading: “April 5 Chicago GI — Civilian Anti-War Demonstration Student Mobilization Committee.”
- Shaw High School maintained a long-standing rule barring “buttons, badges, scarves, and other means of identifying themselves as supporters of a cause or bearing any messages unsupportive of education.”
- The school had a racially mixed student body and a history of racial tension and disturbances; the rule was justified as supporting discipline and an academic environment.
- On March 11, 1969, Guzick and another student brought pamphlets advocating attendance at the same anti-war demonstration referenced on the button and sought permission to distribute them.
- The principal denied permission to distribute the pamphlets and directed both students to remove their buttons under the rule.
- The other student complied; Guzick refused, asserting he had a constitutional right to wear the button based on Supreme Court precedent.
- The principal suspended Guzick and advised the suspension would continue until Guzick complied; Guzick did not return to school.
- Guzick sued seeking injunctive relief, declaratory relief, and damages for each day of school missed; the district court dismissed the complaint.

## Issues

1. Whether enforcing a long-standing, content-neutral rule prohibiting pin-on buttons and similar symbols in a public high school violates the First Amendment when applied to a student wearing an anti-war button.
2. Whether the school’s asserted interest in preventing disruption and maintaining discipline in a tense environment justifies the restriction on student symbolic expression.
3. Whether the case is controlled by student-speech principles recognized in *Tinker* or is distinguishable because the school rule was generally applicable rather than viewpoint-specific.

## Decision

- The Sixth Circuit affirmed the district court’s dismissal of Guzick’s complaint.
- The court held that the school’s no-button policy, as a long-standing and generally applicable rule, could be enforced without violating the First Amendment.
- The court distinguished *Tinker* on the ground that *Tinker* involved a targeted prohibition of a particular anti-war symbol, while Shaw High School’s rule barred non-educational symbols across the board.
- The court accepted the school’s disciplinary rationale, including concern that cause-related symbols could aggravate tensions and disrupt the educational process.
- A dissent argued the majority misapplied *Tinker* and gave excessive deference absent a sufficient showing of disruption.

## Legal Principles

- Public schools may enforce content-neutral, generally applicable restrictions on student symbolic attire when reasonably connected to maintaining order and preventing material disruption.
- *Tinker* bars viewpoint-specific suppression of student expression; it does not categorically prevent schools from regulating symbolic expression through neutral rules.
- Courts may give weight to school administrators’ judgments about the likelihood of disruption, particularly where the record reflects prior disturbances and a volatile school environment.
- Discipline imposed for refusal to comply with a reasonable, uniformly enforced regulation may be upheld where the regulation is not a pretext for suppressing a particular viewpoint.

## Conclusion

The Sixth Circuit upheld a public high school’s uniform prohibition on pin-on buttons and similar symbols and sustained the suspension of a student who refused to remove an anti-war button, treating the rule as a content-neutral discipline measure justified by disruption concerns rather than as viewpoint discrimination.


Guzick v. Drebus, 431 F.2d 594 (6th Cir. 1970)