In May 1983, students in the Journalism II class at Hazelwood East
High School in St. Louis, Missouri, created the final edition of the
school paper, the Spectrum. Before publishing the paper, they submitted
it to their advisor, Howard Emerson, so he could review it. Emerson was
new to the job, so he followed the procedures of the previous advisor.
Those guidelines required him to give Principal Robert Reynolds, the
opportunity to review the paper before it was published.
When Principal Reynolds reviewed the paper, he found two articles
that concerned him. The first dealt with the issue of teen pregnancy. It
included comments from pregnant students at the school. To protect
their privacy, names were not given. However, when Reynolds read the
article, he realized that the details in the article would make it easy
for other students to identify the pregnant teens. He also noticed that
the article mentioned sex and birth control. He did not think that
students in ninth grade should be reading about sex and birth control.
The second article addressed the issue of divorce. Like the first
article, this one included personal information. One student, whose
parents were divorced, made negative comments about her father. She said
that her father was always out with the guys and that her father didn't
spend enough time with the family. Principal Reynolds was troubled by
the fact that the father had not been given a chance to defend himself
by responding to his daughter's comments.
Reynolds wanted the journalism students to modify the articles.
However, it was almost the end of the school year. If they took the time
to revise, they would miss the deadline for publishing the newspaper.
If that happened, the other students might never get to read the paper.
He felt like he had to act quickly, so he told Emerson to delete the two
pages with the offending articles and publish the rest of the Spectrum.
He told his supervisors about this decision and they agreed with him.
The students had worked hard on the paper and felt that they had
followed proper journalism procedures. If they had been approached about
the problems, they may have been able to correct them. They were upset
to find out instead that two pages, which included a number of
nonoffensive articles, had been deleted. They felt that their First
Amendment rights had been violated. They took the case to the U.S.
District Court for the Eastern District of Missouri.
The Court did not agree with the students. In the ruling, the judges
said that school officials may impose limits on students' speech in
activities that are "an integral part of the school's educational
function" as long as their decision "has a substantial and reasonable
basis." In other words, the Court felt that if the school has a good
reason to do so, it can place limits on curricular activities, such as
the publication of the school newspaper.
Unhappy with the outcome, the students appealed their case to the
Court of Appeals for the Eighth Circuit Court. This court reversed the
decision of the lower court, saying that the students' First Amendment
rights were violated. In the opinion, the Court explained that the
newspaper was part of the school curriculum but was also a "public
forum." As a public forum, the newspaper was "intended to be and
operated as a conduit for student viewpoint". Because the paper was a
forum for student discussion, the principal or other officials could
censor it only when "necessary to avoid material and substantial
interference with school work or discipline . . . or the rights of
The school appealed the decision of the Court of Appeals and the
Supreme Court of the United States agreed to hear the case. In
determining whether or not students' rights were violated, it would
consider whether or not the student newspaper was a public forum and
whether the First Amendment "requires a school affirmatively to promote
particular student speech."
Questions to Consider
Why did the newspaper advisor give the paper to Principal Reynolds for review? Was that standard procedure?
What concerns did Principal Reynolds have regarding the two
articles? Were these legitimate concerns? Were there other ways that the
principal could have handled the situation?
Do you think Principal Reynolds was justified in deleting the two
pages of the paper? Should a principal be able to censor student
newspapers? If so, under what conditions?
What rights did the students believe had been violated?
Were there any steps the students could have taken other than filing a lawsuit?
Should a principal or other school authority be able to silence
other forms of student speech? If so, under what conditions? How does
speech by an individual student differ from speech by the school