Hazelwood School District v.

Kuhlmeier
PETITIONER

Hazelwood School District

RESPONDENT

Kuhlmeier
LOCATION

Hazelwood East High School

DOCKET NO.

86-836
DECIDED BY

Rehnquist Court (1987-1988)

LOWER COURT

United States Court of Appeals for the Eighth Circuit

CITATION

484 US 260 (1988)

ARGUED

Oct 13, 1987

DECIDED

Jan 13, 1988

Facts of the case

Background
Cathy Kuhlmeier, Leslie Smart, and Leanne Tippett, all juniors at Hazelwood East High School in St.
Louis, Missouri, helped write and edit the school paper, the Spectrum, as part of Journalism II
class. The May 13th 1983 issue of the paper was to include articles about the impact of divorce on
students and teen pregnancy. The divorce article featured a story about a girl who blamed

her father's actions for her parents' divorce. The teenage pregnancy article featured
stories in which pregnant students at Hazelwood East shared their experiences. To
ensure their privacy, the girls' names were changed in the article. Upon receiving the page
proofs for the May 13 issue, Robert E. Reynolds, the school principal, found two of the articles in the
issue to be inappropriate, saying they were too sensitive for younger students and contained too
many personal details. He concluded that journalistic fairness required that the father in the

divorce article be informed of the story and be given an opportunity to comment. He

also stated his concerns that simply changing the names of the girls in the teenage
pregnancy article may not be sufficient to protect their anonymity and that this topic may
not be suitable for the younger students. Reynolds ordered that the pages on which the

Hazelwood School District v. Kuhlmeier

articles appeared be withheld from publication. Because there was no time to edit the paper if

it were to go to press before the end of the school year, entire pages were eliminated.
The student journalists then brought suit to the U.S. District Court for the Eastern
District of Missouri, alleging that their First Amendment rights to freedom of speech had
been violated. The students sought a declaration that their First Amendment
and Fourteenth Amendment rights had been violated by undue actions of a public
official, as well as injunctive relief and monetary damages.

Question
Did the principal's deletion of the articles violate the student's rights under the First Amendment?

Conclusion

53 DECISION FOR HAZELWOOD SCHOOL DISTRICT

MAJORITY OPINION BY BYRON R. WHITE

No. In a 5-to-3 decision, the Court held that the First Amendment did not require schools to
affirmatively promote particular types of student speech. The Court held that schools must be able to
set high standards for student speech disseminated under their auspices, and that schools retained
the right to refuse to sponsor speech that was "inconsistent with 'the shared values of a civilized
social order.'" Educators did not offend the First Amendment by exercising editorial control over the
content of student speech so long as their actions were "reasonably related to legitimate
pedagogical concerns." The actions of principal Reynolds, the Court held, met this test.

Impact
Schools may censor newspapers and restrict other forms of student expression, including
theatrical productions, yearbooks, creative writing assignments, and campaign and graduation
speeches. But the Court's ruling in Hazelwood encourages schools to look closely at a student
activity before imposing any restrictions and to balance the goal of maintaining high standards
for student speech with students' right to free expression.