Landmark Supreme Court Case · Student speech and press

Hazelwood School District v. Kuhlmeier (1988)

Decided
1988
Vote
5–3
Opinion
Justice Byron White
Constitutional provisions

Facts of the case

Students in a journalism class at Hazelwood East High School in Missouri produced a school-sponsored newspaper, the Spectrum. The principal removed two pages containing articles about student pregnancy and the effects of divorce on students. He was concerned about student privacy and about content inappropriate for younger students. Student staff members, including Cathy Kuhlmeier, sued.

The constitutional question

Does the First Amendment prevent school officials from censoring a school-sponsored student newspaper?

The decision

No. Educators may exercise editorial control over the style and content of student speech in school-sponsored activities, such as a newspaper produced as part of a class, as long as their actions are "reasonably related to legitimate pedagogical concerns."

The Court's reasoning

The newspaper was part of the curriculum, not a public forum. The school could make sure that its own sponsored publications met educational standards.

Why it matters

It gave schools more authority over school-sponsored expression and distinguished it from personal student expression, which is still protected under Tinker. Some states have since passed laws giving student journalists more protection.