Bronson McClelland was the starting quarterback at a Texas public high school. After a heated football game, he exchanged taunts with students from a rival school at an off-campus restaurant and sent a short Snapchat video containing profanity, a racial slur, and language about putting someone in the hospital. The video spread online and drew media attention. School officials removed McClelland as team captain and suspended him from games.

McClelland argued that the school had punished him for off-campus speech protected by the First Amendment. He also challenged the athletic code as overly broad. The defendants argued that officials were entitled to qualified immunity and that the school board itself had not adopted or approved an unconstitutional policy.

The Fifth Circuit affirmed dismissal. It did not announce a broad rule that all similar off-campus speech is unprotected. Instead, it held that the law was not clearly established enough at the time of the 2019 incident to make the principal personally liable for damages. The court also found insufficient allegations tying the school board to the challenged discipline and rejected the overbreadth claim.

The case demonstrates the importance of qualified immunity in constitutional lawsuits. A student may raise a serious First Amendment question yet still lose a damages claim if existing precedent did not clearly tell the official that the particular discipline was unconstitutional when it happened.