Facts
- Hazelwood East High School produced The Spectrum, a student newspaper created in a Journalism II class as part of the curriculum.
- The newspaper was school-sponsored: funded by the school and supervised by a faculty adviser, with administrative review before publication.
- For an issue near the end of the school year, the faculty adviser submitted page proofs to the principal for review.
- Two pages contained an article about student pregnancy and an article about the effects of divorce on students.
- The principal objected to the pregnancy article because unnamed students could be identifiable and because references to sexual activity and birth control were, in his view, unsuitable for younger students.
- The principal objected to the divorce article because it named a student alleging misconduct by her father and the parents had not been given an opportunity to respond or consent.
- Believing there was insufficient time to revise, the principal directed that the two entire pages be removed, including unrelated material on those pages.
- Student staff members sued, alleging the deletion was an unconstitutional prior restraint.
- The district court ruled for the school; the court of appeals reversed; the Supreme Court reversed the court of appeals.
Issues
- Whether a school-sponsored, curricular student newspaper is a public forum for student expression such that censorship is subject to heightened First Amendment limits.
- Whether school officials violate the First Amendment by deleting student articles from a school-sponsored newspaper based on educational and appropriateness concerns.
Decision
- The Supreme Court held, 5–3, that the principal’s deletion of the pages did not violate the student journalists’ First Amendment rights.
- The Court concluded that The Spectrum was not a public forum; it was a school-sponsored curricular activity subject to teacher and administrative oversight.
- The Court ruled that educators may exercise editorial control over school-sponsored student expressive activities when their actions are reasonably related to legitimate pedagogical concerns.
- The principal’s reasons—student privacy, suitability of sexual-content references for younger students, and fairness to parents implicated by allegations—were deemed legitimate educational concerns under that standard.
- The judgment for the school district was reinstated.
Legal Principles
- Student speech rights in public schools are applied in light of the school’s educational setting and are not identical to adult speech rights in other contexts.
- School facilities become public forums only if school authorities, by policy or practice, open them for indiscriminate expressive use; absent that, officials may impose reasonable restrictions consistent with the intended purpose.
- For school-sponsored expressive activities that may reasonably be seen as bearing the school’s imprimatur, educators may regulate style and content if reasonably related to legitimate pedagogical concerns.
- The standard governing independent student expression (substantial disruption) does not control when the speech is part of a school-sponsored curricular activity.
Conclusion
The Court upheld a public high school’s authority to remove articles from a curricular, school-sponsored student newspaper, holding that editorial control is constitutionally permitted when reasonably connected to legitimate educational objectives and the publication has not been opened as a public forum.