Hazelwood, the Supreme Court determined that a high school newspaper produced as part of a journalism class was not a public forum. Citing Perry, the Court wrote: "Hence, school facilities may be deemed to be public forums only if school authorities have 'by policy or practice' opened those facilities for 'indiscriminate use by the general public,' or by some segment of the public, such as student organizations."6 The majority in Hazelwood also reasoned that because the production of the newspaper was "part of the educational curriculum and a regular classroom activity," it was a nonpublic forum.
Since the Hazelwood decision, many courts have continued to defer to the judgment of school officials. As a result, many forms of censorship that had previously been unacceptable under the Tinker standard of expression have been upheld.
Notes
1 See generally O’Neill, K. F. (2000). "A First Amendment Compass: Navigating the Speech Clause with a Five-Step Analytical Framework," SW Univ. L. Rev., 29 223, 284–289.
2 460 U.S. 37 (198