A young Black student in Massachusetts wore a hairstyle that included braids and beads. School officials enforced a grooming or dress rule that required changes to the hairstyle as a condition of attending school. The student’s family argued, among other things, that the hairstyle expressed cultural identity and therefore deserved First Amendment protection.

The school argued that the First Amendment does not protect every personal choice that has cultural or personal meaning. For conduct to count as “speech,” the law generally asks whether the person intended to communicate a message and whether observers would likely understand that message from the conduct itself.

The federal court dismissed the free-speech claim. It relied on First Circuit precedent holding that a hairstyle, without additional facts showing a clearly understood communicative message, is not automatically expressive conduct covered by the First Amendment. The court therefore did not apply the usual student-speech tests such as Tinker to the hairstyle itself.

The ruling does not say that hairstyles lack cultural importance or that schools may regulate them without limits. Other constitutional provisions and state or federal laws may apply. For First Amendment purposes, however, this court concluded that the complaint did not show enough to treat the hairstyle itself as protected speech.