Hazelwood School District v. Kuhlmeier

Brief Fact Summary. A school principal censored a student newspaper by removing some of the articles prior to publication.

Synopsis of Rule of Law. A school may exercise great control over school-sponsored publications that students and members of the community might reasonably perceive to bear the imprimatur of the school.

Facts. The advanced journalism class was responsible for writing the school paper. Usually 4,500 copies were distributed to the school and members of the community. The school principal always reviewed the page proofs prior to printing. On this occasion, he objected to two of the articles scheduled for inclusion and decided to print the paper without the articles. One described the pregnancy of students and included specific sexual content while the other discussed the impact of divorce on students in the school. The parents of the students did not consent to this article.

Issue. Did school officials violate the students’ First Amendment rights by deleting two pages of the school paper?

Held. No. The school administration had the right to control the style and content of student speech when it is included in the school’s expressive activities.

Dissent. Preserving the school’s educational image is not a legitimate reason for eliminating the articles. The articles were not proven to disrupt the operation of the school in any way.

Discussion. The school has a vested interest in protecting its image and the educational activities of the students. Therefore, it is not forced to promote the expressions of the students simply because its sponsors the event or medium used. The school is allowed to consider the emotional maturity of the audience when choosing to suppress certain forms of speech.