Following is the case brief for Hazelwood School District v. Kuhlmeier, United States Supreme Court, (1988)
Case summary for Hazelwood School District v. Kuhlmeier:
- After submission to the principal for final review, two articles discussing teen pregnancy and divorce were excluded from the school’s newspaper, Spectrum.
- Students challenged this action in district court claiming that exclusion violated their First Amendment right to Freedom of Speech.
- The lower court found for the school district. On appeal the court found for the students and the Supreme Court granted certiorari.
- The Court held that the administration had the right to control student speech when it is included in the school’s expressive activities, such as a magazine.
Hazelwood School District v. Kuhlmeier Case Brief
Statement of the facts:
Student Kuhlmeier and two other Journalism students were staff members of their school newspaper, Spectrum. Prior to issuance, the journalism teacher would gather the articles and submit them to the principal for a final review. Two of the articles included in one of the magazine issues included the topic of divorce and teen pregnancy. The author of the divorce article changed the named of her parents to prevent their identity from being unveiled. The principal directed the teacher to exclude the articles from the publication, claiming that the topics were inappropriate for the students to read and that there was insufficient time to make the appropriate edits by the deadline. In response, Kuhlmeier brought suit in district court claiming that the principal’s decision violated the First Amendment’s right to Freedom of Speech.
The district court found for the school district and Kuhlmeier appealed to the court of appeals. The court of appeals reversed, finding for Kuhlmeier and the school district appealed to the Supreme Court of the United States.
Rule of Law or Legal Principle Applied:
Teachers may carry out editorial control over both the style and content of student speech in school sponsored expressive activities as long as the teacher’s actions are reasonable related to a legitimate pedagogical concerns.
Issue and Holding:
Is the First Amendment violated when a school newspaper deletes an article that is related to a legitimate pedagogical concern? No.
The Court reversed the Judgment of the court of appeals.
Although it is true that students and teachers in public schools do not “shed their constitutional rights to freedom of speech or expression at the schoolhouse gate,” these rights “are not automatically coextensive with the rights of adults in other settings,” and must be applied in light of the “special characteristics of the school environment.”
Students may not be punished for simply expressing their personal views on school premises. The school authorities must produce a reason to believe that such expression will substantially interfere with school work or impinge upon the rights of other students.
The Court held that a school is not obligated to tolerate student speech that is inconsistent with its basic mission of education, as that authority belongs to the school board. The Court outlined that teachers have a responsibility to make sure that students learn whatever lessons the school curriculum and activities are designed to teach, so that readers are not exposed to material beyond their level of maturity. In addition, it is important to make sure that the views or beliefs of individual speakers are not mistakenly attributed to the school.
The Court held that educators do have a duty and right under the Constitution to separate the school from publications that may fall into any of the above categories. In Tinker v. Des Moines, 393 U.S. 503 (1969), this Court set a standard for determining when a school may punish student expression. This standard is not applicable when determining when a school may refuse association by name and resources regarding the distribution of student expression.
Here, the teachers and principal did not offend the First Amendment by exercising editorial control over the style and content of student speech. The speech was expressed in a school magazine, a school sponsored expressive activity, and was proper since it was reasonably related to legitimate pedagogical concerns. The Court held that the principal could have reasonably concluded that including articles discussing subjects such as teenage pregnancy and divorce was inappropriate for the audience of young high school readers. In addition, the principal could have reasonably concluded that the identities of the subjects mentioned in the articles were not protected.
Concurring or Dissenting opinion:
The majority is incorrect, as the principal’s censorship serves no legitimate pedagogical purpose and offers no proof that such student expression can disrupt class work or interfere with the rights of other students. The principal failed to consider less restrictive alternatives, and as a result his actions are unconstitutional.
This case provided school officials with wide discretion to review and exclude student speech related to a legitimate pedagogical interest without violating the First Amendment.