## Facts

- B.L., a freshman at a Pennsylvania public high school, tried out for varsity cheerleading but was assigned to junior varsity.
- On a weekend, off campus, B.L. posted Snapchat images to her private “friends” list expressing frustration with school and cheerleading, including profanity and an obscene gesture.
- Another student screenshot the posts and showed them to a cheerleading coach; some students reported being upset.
- Citing team and school rules against foul language, inappropriate gestures, and negative online posts about cheerleading, coaches and the athletic director suspended B.L. from the junior varsity squad for one year.
- B.L. sued under 42 U.S.C. § 1983, alleging the discipline violated the First Amendment and challenging the rules as overbroad, vague, and viewpoint discriminatory.
- The district court and the court of appeals ruled for B.L.; the Supreme Court granted review to address school authority over off-campus student speech.

## Issues

1. Whether, and to what extent, a public school may regulate and discipline off-campus student speech, including speech on social media.
2. Whether disciplining B.L. for her off-campus Snapchat posts violated the First Amendment under the student-speech standards associated with school disruption.

## Decision

- The Supreme Court affirmed, holding 8–1 that the school’s suspension of B.L. from the cheerleading team violated the First Amendment.
- The Court rejected a categorical rule that student-speech doctrine never applies off campus; schools may regulate some off-campus student speech in certain circumstances.
- Even assuming a disruption-based framework could apply, the school’s asserted interests were insufficient on these facts to justify punishment for B.L.’s off-campus expression.

## Legal Principles

- Students retain First Amendment rights, and a school’s regulatory authority is generally weaker when the speech occurs off campus.
- Features of off-campus speech that reduce school authority include: limited in loco parentis responsibility off campus; the risk of granting schools 24-hour control over student expression; and the school’s interest in protecting unpopular expression as part of civic education.
- Schools may have stronger regulatory interests in certain off-campus contexts, including serious bullying or harassment, threats to students or teachers, academic misconduct, or similar conduct closely tied to school functions.
- Discomfort, offense, or brief discussion among students is not enough; a school must show a sufficiently strong interest (such as substantial disruption or comparable harm) to justify restricting off-campus speech.

## Conclusion

The Court held that disciplining a student for profane, critical off-campus social-media posts violated the First Amendment, while recognizing that public schools may regulate some off-campus speech when the school’s interests are substantially stronger and closely connected to school operations or student safety.


Mahanoy Area Sch. Dist. v. B.L., 594 U.S. 180 (2021)