Hazelwood School District v. Kuhlmeier

United States Supreme Court, 1969

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Can a public school restrict what students can say in a school newspaper?

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You spend weeks interviewing students, checking your facts, and finishing your story. Then, just before the newspaper is printed, your principal removes your article without asking your permission.  Can a school do that?

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That question reached the Supreme Court in 1988, and the answer changed what student journalists can publish in school-sponsored newspapers.

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In 1983, students at Hazelwood East High School wrote two articles for their school newspaper, The Spectrum. One discussed teen pregnancy, while another covered the effects of divorce on students.

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The principal believed the stories contained sensitive topics and worried that some students mentioned in the articles could be identified, even though the articles used fake names. He also thought parents should have been given a chance to respond to the article about the divorce.

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Instead of allowing the newspaper to be published as written, the principal removed both pages containing the stories.

 

Three student journalists sued, arguing that the removal of the articles violated their First Amendment right to free speech.

 

The case eventually reached the Supreme Court.

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The Supreme Court said yes, but only under certain circumstances.

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If a newspaper, yearbook, theater production, or another student publication is sponsored by the school as part of a class or school activity, school officials may exercise editorial control over its content as long as their decision is reasonably related to legitimate educational concerns.

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The Supreme Court ruled 5–3 in favor of the school district.

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The majority explained that school-sponsored publications are different from students speaking on their own. Because the newspaper was created as part of a journalism class and used school resources, readers could reasonably believe it represented the school's message.  As a result, schools have greater control over “expressive activities that students, parents, and members of the public might reasonably perceive to bear the imprimatur of the school.” 

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The Court said schools have a responsibility to ensure school-sponsored publications are appropriate for students and support educational goals. That means administrators can remove articles they believe are unsuitable, poorly researched, or inconsistent with the publication's educational purpose.

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However, the Court also emphasized that schools cannot censor student work simply because they disagree with a student's opinion. Their decisions must be connected to legitimate educational reasons.

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The Supreme Court established that schools may regulate speech that appears in school-sponsored activities and may edit or remove student work if their decision is reasonably related to legitimate educational concerns, including protecting student privacy, ensuring accuracy and quality, keeping material appropriate for the intended audience, and making sure school-sponsored publications meet educational objectives

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This standard gives schools more authority over school-sponsored speech than they have over students' personal expression.

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Hazelwood School District v. Kuhlmeier remains one of the most important student speech cases because it created a major exception to the broader free speech protections recognized in Tinker.

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Tinker recognized that students generally have the right to express their opinions at school unless doing so causes a substantial disruption. After Hazelwood, however, schools can constitutionally exercise control over speech connected with a school-sponsored activity. In those situations, administrators can exercise editorial control when they have a legitimate educational reason.  So whether a student is speaking on their own behalf or on behalf of the school can affect the extent of the student’s First Amendment rights.

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This content is for educational purposes only and does not constitute legal advice. Student-speech cases depend heavily on the specific facts, applicable school policies, and the law in the relevant jurisdiction.  Students or parents with questions about their rights should consult with a licensed attorney.