Facts and Case Summary - Hazelwood v. Kuhlmeier

Decision Date: January 13, 1988

Background

Students in the Journalism II class at Hazelwood East High School in St. Louis, Missouri wrote stories about their peers’ experiences with teen pregnancy and the impact of divorce. When they published the articles in the school-sponsored and funded newspaper The Spectrum, the principal deleted the pages that contained the stories prior to publication without telling the students.

Claiming that the school violated their First Amendment rights, the students took their case to the U.S. District Court for the Eastern District of Missouri in St. Louis. The trial court ruled that the school had the authority to remove articles that were written as part of a class.

The students appealed to the U.S. Court of Appeals for the Eighth Circuit, which reversed the lower court, finding that the paper was a "public forum" that extended beyond the walls of the school.  It decided that school officials could censor the content only under extreme circumstances. The school appealed to the Supreme Court of the United States.

Decision and Reasoning

In a 5-3 ruling, the U.S. Supreme Court held that the principal's actions did not violate the students' free speech rights. The Court noted that the paper was sponsored by the school and, as such, the school had a legitimate interest in preventing the publication of articles that it deemed inappropriate and that might appear to have the imprimatur of the school.

Specifically, the Court noted that the paper was not intended as a public forum in which everyone could share views; rather, it was a limited forum for journalism students to write articles, subject to school editing, that met the requirements of their Journalism II class.