Hazelwood School District v. Kuhlmeier

484 U.S. 260 (1988)

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Nature of the Case

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Facts

The Petitioner, the principal at Hazelwood East High School, objected to publication of articles in the school newspaper that discussed teenage pregnancy and divorce. The principal believed that the article on teenage pregnancy made substantial references to sexuality and birth control topics which were unsuitable for younger students. The principal determined that the article on divorce infringed a student's privacy because it mentioned a student by his real name. The principal directed the journalism students to delete the two articles from its upcoming publication or not to print the newspaper at all. The Respondents, student journalists, pursued a declaratory judgment in District Court under their First Amendment right to Freedom of Speech and injunctive relief. The District Court denied an injunction, holding school officials may impose restraints on students' speech in activities that are '`an integral part of the school's educational function so long as their decision has a substantial and reasonable basis. The Court of Appeals reversed. The court held that Spectrum was a public forum because the newspaper was 'intended to be and operated as a conduit for student viewpoint.' As a public forum school officials could only when '`necessary to avoid material and substantial interference with schoolwork or discipline . . . or the rights of others.'' The court concluded that no tort action for libel or invasion of privacy could have been maintained against the school by the subjects of the two articles or by their families. It held that school officials had violated Respondents' First Amendment rights by deleting the two pages of the newspaper. The U.S. Supreme Court reversed, upholding the principle's actions.