N.J., a middle school student, and A.L., a high school student, wore shirts showing firearm images and expressing support for the right to bear arms. Their schools required them to cover the shirts under dress-code interpretations that prohibited clothing depicting guns, even though the written codes did not specifically list firearm images.

The students argued that the shirts communicated political views protected by the First Amendment. School officials argued that firearm imagery could create anxiety or safety concerns and that the restrictions were reasonable school dress rules.

The Seventh Circuit held that a shirt combining a firearm image with a pro-gun-rights message is speech protected by the First Amendment. It also held that the district court used the wrong legal test when it treated the schools like ordinary nonpublic government forums. Student speech at school is governed by Tinker, which requires a reasonable forecast of material disruption or invasion of others’ rights. N.J.’s claim had become moot because he moved on from the middle school, but A.L.’s claim was sent back for analysis under Tinker.

The case is important because it confirms that political messages on clothing do not become unprotected merely because they include firearm imagery. Schools may still restrict such speech when Tinker’s requirements are met, but they must use the student-speech standard rather than a more permissive forum rule.