Hazelwood School District v. Kuhlmeier

Hazelwood School District v. Kuhlmeier

In Hazelwood School District v. Kulhmeier, the dispute concerned the interrelationship between a school's rights to monitor information and students' First Amendment rights. Hazelwood East High School had a school-sponsored newspaper, the Spectrum. The entire cost of the publication was paid for by the school district. Though school-sponsored, the Spectrum was written and edited by the students. In May of 1983, Robert Reynolds, the school's principle, withheld two pages of the student newspaper from publication. He did so because of his belief that the articles were inappropriate. The articles in question concerned teenage pregnancy and divorce. Reynolds was concerned that, though identified by pseudonyms in the articles, some students could be identified in the articles. He was also concerned that, though one article contained criticisms of a student's parent, who was identifiable from the text of the article, it did not give the father a chance to respond to the criticisms. There was insufficient time to edit the articles to address those concerns, so Reynolds pulled the articles rather than delay publication of the entire paper. Cathy Kuhlmeier and two other students brought suit, alleging that Reynolds' action violated the First Amendment. The trial court ruled in favor of the school district, but the appellate court reversed the trial court's decision. The Supreme Court overruled the Court of Appeals' decision, and determined that such censorship did not amount to a First Amendment violation.

Issue

The question at issue was whether the principle deleting those articles violated the students' First Amendment rights.

Reasoning

The Court placed substantial weight on the fact that the newspaper was school sponsored. That sponsorship seemed to equal promotion. Therefore, the Court determined that a school cannot be required to "affirmatively promote particular types of student speech (Oyez). On the contrary, schools had the right to set standards for student speech. Moreover, schools could refuse to sponsor speech that was "inconsistent with 'the shared values of a civilized social order'" (Oyez). What this amounted to was a reasonableness test. As long as an educator's actions were reasonable related to retaining order in school, then an educator could censor a school-sponsored publication. Reynolds had legitimate reasons for censoring the articles. He was concerned that anonymous sources would be identifiable from the context of one of the articles, and that could lead to disruptions in the classroom. He was also concerned about what appears to be a potential case of libel, because an article was going to publish negative information about a parent without giving the parent an opportunity to respond to the article's allegations. Those were legitimate concerns and gave him the right to censor the articles.

Holding

The Court reversed the decision of the Court of Appeals and determined that Reynolds' censorship of the articles was not a First Amendment violation.

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