The Final Appeal

Final Ruling

On January 18, 1988, the Supreme Court ruled, in a five-to-three decision, that Principal Reynolds and the Hazelwood School District did not violate the students’ freedom of speech. In its decision, the Court held that censoring Spectrum was acceptable because the newspaper was an established part of the school curriculum: thus, administrators had a legitimate interest in removing articles they felt were inappropriate. Spectrum could not be characterized as a public forum because school administrators had not opened up the newspaper to general use by the public. Writing for the majority, Justice White explained that a school need not tolerate student speech that is inconsistent with its basic educational mission, even though the government could not censor similar speech outside the school.

“The question whether the First Amendment requires a school to tolerate particular student speech — the question that we addressed in Tinker — is different from the question whether the First Amendment requires a school affirmatively to promote particular student speech.”

– Justice Byron R. White, Majority Opinion

“Public education serves vital national interest in preparing the Nation’s youth for life in our increasingly complex society and for the duties of citizenship in our democratic Republic. The public school conveys to our young the information and tools required not merely to survive in, but to contribute to, civilized society.”

– Justice William J. Brennan Jr., Dissenting Opinion

The Hazelwood Decision & Student Rights

The decision in Hazelwood v. Kuhlmeier ultimately adjusted the boundaries of students’ freedom of speech rights that were decided in Tinker v. Des Moines (1969). Though students do not shed their rights at the schoolhouse gate, the Supreme Court held that educators and administrators do not offend the First Amendment by exercising editorial control over the style and content of student speech in school-sponsored expressive activities, so long as their actions are reasonably related to legitimate educational concerns.