## Facts

- A public high school’s drama director selected the musical *Pippin* for the spring production as part of the theater-arts curriculum.
- The director edited the script to reduce sexually explicit material after consulting administrators.
- After rehearsals began, a parent complained the play mocked religion and was inappropriate.
- The superintendent investigated and ordered the principal to cancel the production; the school board later affirmed the cancellation after a hearing.
- No spring musical was staged that year, but students were not disciplined for opposing the decision.
- The unedited script remained available in the school library, and students were not barred from reading or discussing the play.
- Parents of cast members sued the superintendent, school board members, and the school district, alleging the cancellation violated students’ First Amendment rights; the district court entered judgment for defendants.

## Issues

1. Whether canceling a school-sponsored dramatic production that was part of the curriculum, based on concerns about sexual and religious themes, violated students’ First Amendment rights.
2. Whether the cancellation was impermissible censorship of student expression or a permissible curricular decision within school officials’ educational authority.

## Decision

- The Third Circuit affirmed the judgment for the defendants.
- The court held that canceling the production did not violate students’ First Amendment rights.
- The court treated the cancellation as a curriculum and pedagogical choice, not suppression of independent student speech.
- The court found significant that students remained free to criticize the decision and to access and discuss the script.

## Legal Principles

- Public school officials have broad discretion to make content-based decisions about curriculum and school-sponsored activities that the school selects, organizes, and presents.
- First Amendment protection for student expression is strongest for student-initiated, noncurricular speech; greater school control is permitted over school-sponsored curricular expression.
- A decision limiting only the official presentation of a work, while leaving students free to read, discuss, and criticize it without punishment, is more likely to be characterized as a curricular selection rather than unconstitutional censorship.
- Courts generally defer to school officials’ educational judgments about age-appropriateness and suitability of curricular materials when reasonably related to legitimate educational concerns.

## Conclusion

The Third Circuit upheld the cancellation of a high school musical as a permissible curricular decision within administrators’ educational authority, concluding the First Amendment did not require the school to stage a particular play and noting the absence of broader suppression or punishment of student expression.


Seyfried v. Walton, 668 F.2d 214 (3d Cir. 1981)