Hazelwood V Kuhlmeier
Hazelwood V Kuhlmeier
Hazelwood V Kuhlmeier
V Kuhleimer
Facts: Petitioners are the Hazelwood School District in St. Louis County, Missouri; school officials, Principal Robert Eugene Reynolds and Howard Emerson, journalism teacher. Respondents are 3 former Hazelwood East students who were staff members of the Spectrum, the school newspaper. They contend that school officials violated their First Amendment rights by deleting two pages of articles from the May 13, 1983, issue of Spectrum. Spectrum was written and edited by Journalism II class at Hazelwood. The newspaper was published every 3 weeks or so during the 1982-1983 school year. More than 4500 copies of the newspaper were distributed to the whole school. The practice at the school during the spring 1983 semester was for the journalism teacher to submit page proofs of each Spectrum issue to Principal Reynolds for his review prior to publication. On May 10, Emerson delivered the proofs of the May 13 edition to Reynolds, who objected to two of the articles scheduled to appear in that edition. One of the stories described 3 Hazelwood East students experiences with pregnancy; the other discussed the impact of divorce on students at school. Reynolds was concerned that although the pregnancy story used false names to keep the identity of these girls a secret, the pregnant students still might be identifiable from the text. The article also had references to sexual activity and birth control, which were inappropriate for some of the younger students in the school. In addition, Reynolds believed that the students parents, with regard to the divorce article, should have been given an opportunity to respond to these remarks or to consent to their publication. He then concluded that due to time constraint, his only option was to publish a four-page newspaper instead of the planned six. He informed his superiors of the decision and the concurred. Respondents subsequently commenced this action in the United States District Court for the Eastern District of Missouri, seeking a declaration that their First Amendment rights had been violated. Their petition was denied. The Court of Appeals reversed the decision and concluded that Spectrums status as a public forum precluded school officials from censoring its
contents except when necessary to avoid material and substantial interference with school work or discipline. Issue: W/N the school officials had violated respondents First Amendment rights by deleting the two pages of the newspaper Held: No violation of the First Amendment
Ratio: Respondents assertion that they had believed that they could publish practically anything in the Spectrum is not credible because every issue published must be approved by the Journalism teacher and still had to be reviewed by the principal prior to publication. Accordingly, school officials are entitled to regulate the contents of the Spectrum in any reasonable manner. In addition, a school must be able to take into account the emotional maturity of the intended audience in determining whether to disseminate student speech on potentially sensitive topics. 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. Accordingly, no violation of First Amendment rights occurred.