I.P. was a high school student in Tennessee who posted three edited images of his principal on Instagram. He made the posts away from school, including during summer break and from home. The images mocked or satirized the principal but did not actually cause a substantial disruption at school. After administrators learned about the posts, I.P. was suspended.

I.P. argued that the memes were protected off-campus speech and that the school lacked evidence to reasonably predict the kind of substantial disruption required by Tinker. The school argued that the images could embarrass the principal, undermine his authority, and lead to disruption among students. The parties also disputed the meaning of the images and what administrators reasonably understood at the time.

The court did not decide which side ultimately wins. It denied both sides’ motions for summary judgment because important factual disputes remained about whether the school’s forecast of disruption was reasonable. A jury must resolve those factual disputes.

The case illustrates why off-campus social-media cases are often highly fact-specific. Under Mahanoy, schools generally have less authority over off-campus speech, but they may still act in some circumstances if they can show a sufficiently strong connection to school interests and a reasonable basis to expect serious disruption.