Facts and Case Summary - Hazelwood v. Kuhlmeier
Facts and case summary for Hazelwood v. Kuhlmeier, 484 U.S. 260 (1988) The First Amendment rights of student journalists are not violated when school officials prevent the publication of certain articles in the school newspaper.
Students enrolled in the Journalism II class at Hazelwood East High School were responsible for writing and editing the school's paper The Spectrum. Two of the articles submitted for publication in the final edition of the paper contained stories on divorce and teenage 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. The school principal felt that the subjects of these two articles were inappropriate. 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. As a result, he prohibited these articles from being published in the paper.
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 U.S. District Court concluded that they were not. The students appealed to the U.S. Court of Appeals for the Eighth Circuit, which reversed the ruling, stating that the students' rights had been violated. The school appealed to the U.S. Supreme Court, which granted certiorari.
Lower Court: Eighth Circuit
Lower Court Ruling: Held: The decision of the principal to prohibit the publishing of certain student articles deemed to be inappropriate violates the student journalists' First Amendment free speech rights.
Supreme Court Ruling: Held: Reversed the decision of the Eighth Circuit. The decision of the school principal to prohibit the publishing of certain articles deemed to be inappropriate does not violate the student journalists' First Amendment right of freedom of speech.
Supreme Court Vote: 5-3
Argued: October 13, 1987
Decided: January 13, 1988
Majority Opinion: Justice White (joined by Chief Justice Rehnquist and Justices O'Connor and Scalia)
Dissenting Opinion: Justice Brennan (joined by Justices Marshall and Blackmun dissenting)
Does the decision of a principal to prohibit the publishing of certain articles, which he deems inappropriate, in the school newspaper violate the student journalists' First Amendment right of freedom of speech?
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 pursuant to the requirements of their Journalism II class, and subject to appropriate editing by the school.
Key Points to Remember
- The First Amendment protects the right to freedom of speech.
- The Spectrum was written by students in the Journalism II course as part of the requirements of that course.
- The articles in question were about divorce and teenage pregnancy. The subjects of both of these stories were students at Hazelwood East High School.
- The divorce article featured a story in which a girl blamed her father's actions for her parents' divorce, but the author did not adhere to journalistic standards by informing the father of the story and giving him an opportunity to respond.
- Although their names were changed, the principal was concerned that students may be able to recognize the identity of the girls who were interviewed for the pregnancy article.
Haynes, Charles C., et al. The First Amendment in Schools: A Guide from the First Amendment Center. Virginia. ASCD (Association for Supervision and Curriculum Development) publications, 2003.
Hazelwood School District v. Kuhlmeier, 484 U.S. 260 (1988) (Majority and dissenting opinions).
Raskin, Jamin B. We the Students: Supreme Court Cases for and About Students, 2nd ed. Washington, D.C. Congressional Quarterly Press, 2003.