The Supreme Court created a second distinction from Tinker in Hazelwood School District v. Kuhlmeier. In Kuhlmeier, the principal of Hazelwood East High School removed two articles written by students from the school newspaper. One of the stories described three unidentified Hazelwood East students' experiences with pregnancy; the other discussed the impact of divorce on named students at the school. The principal was concerned over the content of two stories, one that described the experiences of three pregnant Hazelwood high school students and another that discussed the impact of divorce on students at the school. The students sued claiming a violation of their First Amendment rights.
The Supreme Court acknowledged both Tinker and Fraser in their analysis finding that the school was not a public forum and the school had a right to control the paper as part of the schools’ curriculum. The Court ruled in favor of the school district stating "educators do not offend the First Amendment by exercising editorial control over the style and content of student speech in school-sponsored expressive activities so long as their actions are reasonably related to legitimate pedagogical concerns."
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