This memo introduces the information regarding the case of Mahanoy Area School District v. B.L. The case was discussed at the Supreme Court of the United States (SCOTUS) in 2021. It addresses the issue of freedom of speech, guaranteed by 1st Amendment of the United States constitution. More specifically, the case in question reflects the complexity of this notion in today’s environment, as the means of communication evolve along with technology. Under these circumstances, the borderline between freedom of speech and disrupting behavior becomes vague. With the emerging opportunities for instant communication, people are able to broadcast their opinions to broader audiences.
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The appeal to the Supreme Court was made the Mahanoy Area school district, representing the faculty of this community. Their motion served to defend the honor of Mahanoy Area High School and its teaching staff who felt offended by the comments made by one of the students. More specifically, the school districted insisted on its right to supervise the behavior of the students both within and outside classroom boundaries. The other party is Mahanoy Area High School’s female student named Brandi Levy (or B.L. in case records), as well as her family (Mahanoy Area School District v. B. L., 2021). The case continues a series of hearings that preceded its discussion at the SCOTUS.
The case originates from an incident that occurred in the digital environment. Brandi Levy was the school’s cheerleader at the time when she learned that she had not received the desired position in the varsity squad. Feeling frustrated by the situation, Levy released a Snapchat post reading “F..k school f..k softball f.k cheer f..k everything.” (Hudson, 2021, para. 2). In response to the offensive comments, school’s officials had Brandi Levy suspended from cheerleading for one year. The latter did not accept the punishment and the case escalated to the level of the Supreme Court.
Parties’ Positions and Arguments
Mahanoy Area school district passed a motion, insisting on the rightful nature of the school officials’ decision to suspend B. L. from participating in cheerleading activities. As per their position, it is an educators’ right to supervise the behavior of their students within and outside the classroom environment. Levy compromised her integrity by posting an overly emotional, denigrating post regarding the school and cheerleading. Furthermore, her choice of language did not meet the standards of an educated young person of the 21st century. Levy’s actions are said to be in the domain of disruptive behavior, as ruled in Tinker et al. v. Des Moines Independent Community School District et al. (1968). On the other hand, Levy and her family insist on a student’s right of free speech, as guaranteed by the Constitution of the United States. Levy had an opinion regarding the matter, and, as controversial as it was, she was entitled to expressing it. There was not an element of disruptive behavior, making the case different from Tinker. In addition, the incident occurred outside of school or any classroom activities, limiting the educators’ authority over the matter.
Holding of the Court before the SCOTUS
Before the case escalated to the level of the Supreme Court, there were prior hearings. Having learnt of the school authorities’ decision to suspend Levy, her parents sued the institution in federal court. The court agreed with their position that the behavior of students online and outside classroom activities does not fall into the jurisdiction of the school. Such cases are the responsibility of the parents, making them the ultimate judges of whether the adolescent’s behavior is appropriate. Likewise, the U.S. Court of Appeals for the 3rd Circuit sided with Levy, thus confirming the ruling of the federal court. According to Hudson (2021), it is also noted that the substantial disruption standard of the Tinker case does not apply in this scenario. Furthermore, even Levy’s behavior matched its criteria, it “does not apply to off-campus, online student speech” (Hudson, 2021, para. 4). After these decision, Mahanoy Area school district addressed the Supreme Court for a final resolution of the argument.
Supreme Court Majority and Dissent
SCOTUS ruled by an 8-1 majority that previous courts’ decisions were in line with the law and precedents. Justice Stephen Breyer noted that educational institutions do not exercise the authority over students’ behavior in the digital space, especially when said behavior is exhibited in a student’s own time. Online speech remains within the parents’ zone of control, thus limiting the school’s ability to police it. Justice Clarence Thomas dissented, insisting on the historic role of schools as the cornerstone of ethical upbringing (Mahanoy Area School District v. B. L., 2021). From this perspective, educators’ role transcends mere delivery of knowledge, entering the territory of nurturing personal traits.
The case in question creates an important precedent in the age of social media and the Internet. With today’s spread of modern technology, young people find it easier to deliver their messages to broader audiences. From one perspective, this remains their form of self-expression and socialization, which is likely to fall into the 1st Amendment area. Kim (2021) notes this case reflects the important role of social networks as a fully developed communication medium. In this regard, I am inclined to agree with the decision of the SCOTUS, as speech on the Internet equally deserves freedom. Nevertheless, there should be a right balance so that online behavior does not become disruptive (Bonds, 2021). Therefore, to avoid controversy in the future, a clearer definition of disruptive student behavior in the contemporary reality is needed.
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Bonds, V. R. (2021). Tinkering with the schoolhouse gate: The future of student speech after Mahanoy Area School District v. B.L.. Entertainment Law Review, 42(2). Web.
Hudson, D. L. (2021). Mahanoy Area School District v. B.L.: The court protects student social media but leaves unanswered questions. SSRN. Web.
Kim, R. (2021). Under the law: Regulating student speech in the Snapchat era. Phi Delta Kappan, 102(6), 62–63. Web.
Mahanoy Area School District v. B. L. (2021). Supreme Court of the United States. Web.
Tinker et al. v. Des Moines Independent Community School District et al. (1968). Oyez. Web.