## Facts

- A public school district adopted a high-school graduation requirement (with certain special-education exceptions) mandating completion of 60 hours of unpaid community service over four years.
- The requirement operated as a course program; hours could be completed after school, on weekends, or during summers.
- Students could select from approved organizations or propose alternative service experiences for approval.
- The district stated educational objectives, including teaching life skills, the significance of service, and civic responsibility.
- Two students and their parents challenged the requirement, while acknowledging they engaged in voluntary service, objecting only to service being a mandatory condition for a diploma.
- The plaintiffs sought declaratory and injunctive relief, alleging (1) compelled ideological expression in violation of the First and Fourteenth Amendments and (2) involuntary servitude in violation of the Thirteenth Amendment.
- The district court granted summary judgment for the school district; the plaintiffs appealed.

## Issues

1. Whether requiring 60 hours of community service as a condition of high-school graduation compels ideological expression in violation of the First and Fourteenth Amendments.
2. Whether the unpaid service requirement, enforced through denial of a diploma for noncompliance, constitutes involuntary servitude prohibited by the Thirteenth Amendment.

## Decision

- The court affirmed summary judgment for the school district.
- The community-service requirement did not compel students to affirm or endorse an ideology and therefore did not violate the First Amendment.
- The requirement was not involuntary servitude within the meaning of the Thirteenth Amendment.

## Legal Principles

- Compelled-speech doctrine is triggered when the state requires a person to affirm, display, or profess a specific ideological message; a curricular requirement to perform service, without mandated affirmation of belief, is not treated as compelled ideological speech.
- Conduct is not constitutionally “expressive” merely because it has moral, civic, or educational aims; incidental or diffuse expressive effects are generally insufficient to establish compelled expression.
- Program flexibility—student choice among service placements and the absence of required statements of agreement—reduces any attribution of a state-imposed viewpoint to the student.
- The Thirteenth Amendment targets slavery, peonage, and comparable coerced labor backed by severe coercion; modest, generally applicable public or educational obligations lacking physical compulsion or criminal sanctions do not amount to involuntary servitude.
- Unpaid service incorporated into an educational curriculum for students’ benefit is materially different from compelled labor imposed for another’s private economic gain.

## Conclusion

The Third Circuit held that a public school may condition graduation on completion of a limited, unpaid community-service program structured as a curricular requirement, because it neither compels students to express an ideological belief nor imposes involuntary servitude as understood under the Thirteenth Amendment.


Steirer v. Bethlehem Area Sch. Dist., 987 F.2d 989 (3d Cir. 1993)