## Facts

- A public high school student (B.L.) tried out for varsity cheerleading and was placed on junior varsity.
- Cheerleaders were required to follow team rules, including expectations of respectful conduct and restrictions on posting negative content about cheerleading, cheerleaders, or coaches online.
- On a weekend, off campus, B.L. posted to her private Snapchat story a photo with an obscene caption criticizing school, sports, cheer, and “everything,” visible for 24 hours to about 250 friends.
- A teammate shared screenshots with coaches; some students were upset and the posts were discussed at school.
- Coaches suspended B.L. from the cheerleading team for one year for violating team rules; school administrators upheld the discipline.
- B.L. sued under 42 U.S.C. § 1983, claiming the discipline violated her First Amendment rights.
- The district court granted relief for B.L.; the Third Circuit affirmed. The Supreme Court granted certiorari.

## Issues

1. To what extent may a public school regulate and discipline a student for off-campus social-media speech.
2. Whether the school district violated the First Amendment by suspending B.L. from cheerleading for her off-campus Snapchat posts.

## Decision

- The Supreme Court affirmed judgment for B.L. by an 8–1 vote.
- The Court rejected a categorical rule that schools lack authority over all off-campus speech, but held schools generally face a heavy burden to justify regulating off-campus expression.
- On these facts, the school’s interests did not justify punishing B.L.’s crude, off-campus criticism, and the one-year suspension violated the First Amendment.

## Legal Principles

- Public schools may regulate student speech when justified by sufficiently strong school interests, including under the substantial-disruption framework associated with student-speech doctrine, but the off-campus setting materially affects the analysis.
- Off-campus speech typically implicates: (1) primary parental responsibility rather than school authority; (2) the risk of effectively regulating student expression throughout the entire day; and (3) the school’s role in protecting unpopular expression.
- Schools may have stronger interests in regulating off-campus speech in specific contexts (e.g., severe bullying or harassment, threats targeting students or staff, or breaches of school security).
- Crude or vulgar criticism of school-related matters, expressed off campus to a private audience and causing at most minor disruption, is protected by the First Amendment.

## Conclusion

The Court held that a public school violated the First Amendment by suspending a student from an extracurricular activity for an off-campus Snapchat post criticizing school and cheerleading, while recognizing limited circumstances in which schools may regulate off-campus student speech.


Mahanoy Area Sch. Dist. v. B.L., 141 S. Ct. 2038 (2021)