Hazelwood School District v. Kuhlmeier
Hazelwood School District et al. v. Kuhlmeier et al., 484 U.S. 260 (1988), was a landmark decision by the Supreme Court of the United States which held, in a 5–3 decision, that student speech in a school-sponsored student newspaper at a public highschool could be censored by school officials without a violation of First Amendment rights if the school's actions were "reasonably related" to a legitimate pedagogical concern.
| Hazelwood v. Kuhlmeier | |
|---|---|
Supreme Court of the United States | |
| Argued October 13, 1987 Decided January 13, 1988 | |
| Full case name | Hazelwood School District, et al. v. Kuhlmeier, et al. |
| Docket no. | 86-836 |
| Citations | 484 U.S. 260 (more) 108 S. Ct. 562; 98 L. Ed. 2d 592; 1985 U.S. LEXIS 310; 56 U.S.L.W. 4079; 14 Media L. Rep. 2081 |
| Argument | Oral argument |
| Case history | |
| Prior | Kuhlmeier v. Hazelwood Sch. Dist., 596 F. Supp. 1422 (E.D. Mo. 1984); 607 F. Supp. 1450 (E.D. Mo. 1985); reversed, 795 F.2d 1368 (8th Cir. 1986); cert. granted, 479 U.S. 1053 (1987). |
| Court membership | |
| |
| Case opinions | |
| Majority | White, joined by Rehnquist, Stevens, O'Connor, Scalia |
| Dissent | Brennan, joined by Marshall, Blackmun |
| Laws applied | |
| U.S. Const. amend. I | |
The case concerned the censorship of two articles in The Spectrum, the student newspaper of Hazelwood East High School in St. Louis County, Missouri, 1983. When the school principal removed an article concerning divorce and another concerning teen pregnancy, the student journalists sued, claiming that their First Amendment rights had been violated. A lower court sided with the school, but its decision was overturned by the U.S. Court of Appeals for the Eighth Circuit, which sided with the students and found that the paper was a "public forum" comparable to speech outside an educational setting. The Supreme Court reversed, noting that the paper was established by school officials as a limited forum for the purpose of a supervised journalism class, and could be censored even though similar speech in an off-campus or independent student newspaper would be protected.
The case, and the earlier Tinker v. Des Moines Independent Community School District (1969), are considered landmark decisions for defining the right of expression for students in public schools. While subsequent court rulings have varied on when Kuhlmeier applies, the case remains a strong precedent in the regulation of student speech. However, the state statutes protecting student free expression, enacted by 17 states as of March 23, 2023, most in response to the limitations of Kuhlmeier, typically adopt the more protective Tinker precedent.