Hazelwood School District v. Kuhlmeier

Hazelwood v. Kuhlmeier
Argued October 13, 1987
Decided January 13, 1988
Full case nameHazelwood School District, et al. v. Kuhlmeier, et al.
Docket no.86-836
Citations484 U.S. 260 (more)
108 S. Ct. 562; 98 L. Ed. 2d 592; 1985 U.S. LEXIS 310; 56 U.S.L.W. 4079; 14 Media L. Rep. 2081
ArgumentOral argument
Case history
PriorKuhlmeier v. Hazelwood Sch. Dist., 596 F. Supp. 1422 (E.D. Mo. 1984); 607 F. Supp. 1450 (E.D. Mo. 1985); reversed, 795 F.2d 1368 (8th Cir. 1986); cert. granted, 479 U.S. 1053 (1987).
Court membership
Chief Justice
William Rehnquist
Associate Justices
William J. Brennan Jr. · Byron White
Thurgood Marshall · Harry Blackmun
John P. Stevens · Sandra Day O'Connor
Antonin Scalia
Case opinions
MajorityWhite, joined by Rehnquist, Stevens, O'Connor, Scalia
DissentBrennan, joined by Marshall, Blackmun
Laws applied
U.S. Const. amend. I

Hazelwood School District et al. v. Kuhlmeier et al., 484 U.S. 260 (1988), was a landmark decision by the Supreme Court of the United States which held, in a 5–3 decision, that student speech in a school-sponsored student newspaper at a public high school could be censored by school officials without a violation of First Amendment rights if the school's actions were "reasonably related" to a legitimate pedagogical concern.[1][2]

The case concerned the censorship of two articles in The Spectrum, the student newspaper of Hazelwood East High School in St. Louis County, Missouri, 1983. When the school principal removed an article concerning divorce and another concerning teen pregnancy, the student journalists sued, claiming that their First Amendment rights had been violated. A lower court sided with the school, but its decision was overturned by the U.S. Court of Appeals for the Eighth Circuit, which sided with the students and found that the paper was a "public forum" comparable to speech outside an educational setting. The Supreme Court reversed, noting that the paper was established by school officials as a limited forum for the purpose of a supervised journalism class, and could be censored even though similar speech in an off-campus or independent student newspaper would be protected.[3]

The case, and the earlier Tinker v. Des Moines Independent Community School District (1969), are considered landmark decisions for defining the right of expression for students in public schools. While subsequent court rulings have varied on when Kuhlmeier applies, the case remains a strong precedent in the regulation of student speech. However, the state statutes protecting student free expression, enacted by 17 states as of March 23, 2023, most in response to the limitations of Kuhlmeier, typically adopt the more protective Tinker precedent.[4][5]

  1. ^ "Hazelwood v. Kuhlmeier". United States Courts. Retrieved January 29, 2024.
  2. ^ "Instead, we hold that educators 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 pedagogical concerns."Kuhlmeier, at 273.
  3. ^ "HAZELWOOD SCHOOL DISTRICT, et al., Petitioners v. Cathy KUHLMEIER et al". LII / Legal Information Institute. Retrieved January 2, 2024.
  4. ^ Student Press Law Center (March 21, 2018). "Washington New Voices bill officially signed into law, becoming 14th state to protect rights of student journalists". Student Press Law Center. Retrieved March 21, 2018.
  5. ^ Center, Student Press Law (March 24, 2023). "West Virginia New Voices Act (2023)". Student Press Law Center. Retrieved May 16, 2023.

© MMXXIII Rich X Search. We shall prevail. All rights reserved. Rich X Search