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Published: June 29, 2011

Hazelwood School District v. Kuhlmeier

A 1988 U.S. Supreme Court decision that gave a Missouri high school principal the right to delete from the student newspaper student articles he deemed inappropriate. The case proved another in a continuing series of confusing and constantly shifting decisions over FIRST AMENDMENT free-speech rights of minors—in this case, the rights of students who wrote and edited the school newspaper as part of a journalism class. Because the newspaper was school owned and operated and used as a pedagogical tool, the Court found that the principal (and, by inference, other educators) did not violate student free-speech or free-press rights by controlling style and content of student expression. Such controls were deemed an effort to teach students better techniques of writing and evaluation, much as style and content are teacher-directed in literature or history essays.
The Court distinguished between the Hazelwood School District and the 1969 case of Tinker v. Des Moines Independent School District, in which it ruled that students had the right to wear antiwar armbands in school. Pointing out that the “Constitution does not stop at the public school doors,” the Court nevertheless left educational authorities with the right to curtail student free speech when it “materially and substantially” disrupted the educational process. Neither case clarified the issue for colleges, where students have not only reached the age of majority, but also often operate school newspapers independently.