Thursday, July 21, 2011
Tuesday, July 19, 2011
A Win for Students’ Off-Campus Expression
Martha McCarthy
Chancellor’s Professor and Chair
Educational Leadership & Policy Studies
Indiana University
On June 13, 2011, the Third Circuit en banc rendered decisions in Layshock v. Hermitage School District (2011 U.S. App. LEXIS 11994) and J.S. v. Blue Mountain School District (2011 U.S. App. LEXIS 11947), which had been eagerly anticipated for more than a year. The appeals court en banc held in both cases that school districts cannot punish students for expression that originated outside school and did not create a substantial disruption of the school environment. The recent rulings were precipitated by opposing Third Circuit panel decisions regarding the school districts’ authority to discipline students for posting vulgar and disparaging mock profiles of their principals on MySpace.
[B]Layshock’s First Amendment Claim[/B]
Justin Layshock, a high school senior, used his grandmother’s computer to post the
parody of his principal, whose profile picture was copied from the school’s website. The vulgar parody linked the principal to drugs, alcohol, and prostitutes. The MySpace profile was widely viewed by students outside school and even by some in the school’s computer class, and Layshock accessed the profile once at school. Several classmates subsequently posted similar profiles, which the principal found demeaning. The principal contacted the police about filing defamation or harassment charges, but no criminal or civil charges were filed. Layshock’s was the least vulgar of the students’ postings, but he was the only student punished. Layshock originally was suspended for 10 days, placed in an alternative education program for the remainder of the year, barred from extracurricular activities, and prohibited from participating in the school’s graduation ceremony, but these disciplinary actions, except for the suspension, were rescinded in exchange for the parents withdrawing their motion for a preliminary injunction. Layshock and his parents challenged the suspension, and the district court granted summary judgment to the Layshocks. The Third Circuit panel affirmed in February, 2010. Applying the disruption standard established in Tinker v. Des Moines Independent School District (503 U.S. 503 (1969)), the appellate panel agreed with the district court that Layshock could not be punished for posting the parody because it did not trigger a substantial disruption of the educational process.
The full Third Circuit Court of Appeals vacated the panel ruling and reheard this case along with J.S. in June 2010 and recently again affirmed the district court’s grant of summary judgment to Layshock on his First Amendment claim. Acknowledging that the parody was not disruptive and thus not excluded from constitutional protection under Tinker, the school district contended that Layshock’s expression was lewd and vulgar, which is not constitutionally protected under the Supreme Court’s ruling in Bethel School District v. Fraser (478 U.S. 675 (1986)). However, the Third Circuit declined to apply Fraser to off-campus lewd and vulgar speech, reasoning that Fraser applies only to student expression occurring at school. Applying Tinker instead, the Third Circuit required the expression to be linked to a school disruption to justify disciplinary action. The court seemed to rely heavily on an earlier Second Circuit decision, Thomas v. Board of Education (607 F.2d 1043 (2d Cir. 1979)), in which the appeals court struck down disciplinary action against students for off-campus distribution of a satirical magazine with some vulgar language as there was no evidence of an adverse impact on the school. The only connection with the school was that students had done some work on the publication in school after hours and stored copies of the publication in a classroom closet. The Third Circuit found the relationship between Layshock’s conduct and the school to be far less than the students’ connection to the school in Thomas. The court concluded that “it would be an unseemly and dangerous precedent to allow the state, in the guise of school authorities , to reach into a child’s home and control his/her actions there to the same extent that it can control” conduct in school-sponsored activities (p. *28). The Third Circuit reasoned that in cases where disciplinary action has been allowed, students’ Internet expression has caused a substantial disruption of the school.
[B]J.S’s First Amendment Claim[/B]
In the second case, two eighth grade female students were suspended for posting on MySpace a parody of their principal created on the weekend at home. These students also used the principal’s picture from the school’s website. The principal was depicted as a sex addict and pedophile who enjoyed “hitting on students and their parents” among other things (p. *4). J.S. originally made the profile public but then limited it to about 20 friends, and no students viewed the profile at school because MySpace was blocked on school computers. The principal was upset and threatened legal action against the families, but after contacting the police he did not file charges. J.S. and her friend were suspended and barred from school functions for 10 days for posting the profile. School authorities asserted that the profile caused a disruption at school (e.g., teachers having to quiet their classes, staff having to alter their schedules to address the issue, students decorating J.S.’s locker when she returned from her suspension).
J.S. and her parents brought suit, and the district court granted the school district’s summary judgment motion on all claims. The court specifically noted that Tinker’s disruption standard did not govern this case because there was no substantial disruption at school. However, the court reasoned that the students could be disciplined under Tinker for expression invading the rights of others, specifically the principal’s rights in this case. Moreover, the court found the vulgar and offensive expression to be unprotected based on Fraser. A divided Third Circuit panel affirmed the district court’s judgment for the school district, concluding that although the incidents of alleged disruption were unpersuasive, school authorities could reasonably forecast a future disruption from the continued posting of the profile.
On the substantive First Amendment question, the Third Circuit en banc by an eight-to-six vote reversed the district court’s grant of summary judgment to the school district, finding a violation of the student’s expression rights. The appeals court relied on the Tinker disruption standard, and in contrast to the appellate panel, the full Third Circuit was hesitant to allow an assessment of possible future disruption to justify disciplinary action against J.S. The court noted that under Tinker, the mere apprehension or fear of disruption was not sufficient to curtail students’ right to silently protest governmental policies by wearing black armbands. The full Third Circuit reasoned that there was no way to know that a disruption would have resulted if the principal had not acted swiftly against the students. As in Layshock, the en banc Third Circuit in J.S. held that Fraser does not authorize schools to punish off-campus lewd and vulgar expression and further held that student expression interfering with the rights of others cannot be curtailed under Tinker unless linked to a school disruption.
[B]Other Claims[/B]
The Third Circuit en banc found the parodies in both cases so outrageous that no one would believe that they were serious. However, the appeals court affirmed the courts below in rejecting the parents’ Fourteenth Amendment claims that the schools’ imposition of discipline for off-campus expression interfered with their liberty rights to control the upbringing of their children. The schools’ actions did not force or prevent the parents from disciplining their children. Also, the Third Circuit did not find the schools’ policies pertaining to the use of technology to be unconstitutionally vague or overbroad.
In both cases, there were concurring opinions. Two justices wrote separately in Layshock to emphasize that Tinker’s disruption standard does apply to students’ off-campus speech that disrupts the school. Conversely, four judges signed a concurrence in J.S., contending that Tinker does not apply to off-campus expression at all. There was no dissent in Layshock, but 6 of the 14 judges dissented in J.S., arguing that school authorities produced sufficient evidence of a school disruption to satisfy Tinker and justify the discipline imposed on J.S. for her off-campus expression.
[B]Implications[/B]
These recent Third Circuit decisions represent a win for students in terms of constitutional protection of their off-campus electronic expression. Also, the court made the most definitive statement to date confining the application of Fraser to expression that occurs at school. While endorsing Tinker’s disruption standard to govern students’ off-campus expression, the Third Circuit judges were not in agreement on the reach of Tinker in this regard. It remains to be seen whether other courts will follow a majority of the Third Circuit in equating off-campus creation and distribution of print material that was at issue in Thomas to off-campus Internet expression that potentially reaches the entire student body.
The Third Circuit distinguished these two cases from the recent Second Circuit opinion involving disciplinary action against a student for her vulgar blog entries from home that school personnel reasonably could forecast would be disruptive; the court found school authorities immune from liability for their actions in this unsettled area of law (Doninger v Schwartz, 2011 U.S. App. LEXIS 8441, 2d Cir., April 25, 2001). The Third Circuit reasoned in part that the student’s disqualification to run for class office in Doninger was a less significant punishment than the suspensions in Layshock and J.S., a conclusion some might question. The Third Circuit also considered the student’s vulgar urging of classmates to criticize school authorities in Doninger to be more detrimental to the school than the posting of fictitious parodies on MySpace.
The Third Circuit’s endorsement of students’ off-campus electronic expression rights may encourage additional harassment and defamation suits initiated by students and school personnel to challenge demeaning and vulgar student Internet expression. Also, public schools may be motivated to strengthen their Internet acceptable use policies and to become more assertive in reaching out to parents regarding the potential negative impact of their children’s harmful expression via social networks. And there undoubtedly will be more First Amendment challenges to MySpace and Facebook postings, with a range of possible judicial opinions. Some courts may follow the Third Circuit in siding with students’ expression rights, whereas others may back the schools or agree with the Second Circuit that the law is too unsettled for liability to be assessed against school authorities. As technology becomes increasingly integrated into daily life, clear guidance on the legality of electronic expression is needed, so it seems likely that the Supreme Court eventually will have to render an opinion on this volatile topic.
Chancellor’s Professor and Chair
Educational Leadership & Policy Studies
Indiana University
On June 13, 2011, the Third Circuit en banc rendered decisions in Layshock v. Hermitage School District (2011 U.S. App. LEXIS 11994) and J.S. v. Blue Mountain School District (2011 U.S. App. LEXIS 11947), which had been eagerly anticipated for more than a year. The appeals court en banc held in both cases that school districts cannot punish students for expression that originated outside school and did not create a substantial disruption of the school environment. The recent rulings were precipitated by opposing Third Circuit panel decisions regarding the school districts’ authority to discipline students for posting vulgar and disparaging mock profiles of their principals on MySpace.
[B]Layshock’s First Amendment Claim[/B]
Justin Layshock, a high school senior, used his grandmother’s computer to post the
parody of his principal, whose profile picture was copied from the school’s website. The vulgar parody linked the principal to drugs, alcohol, and prostitutes. The MySpace profile was widely viewed by students outside school and even by some in the school’s computer class, and Layshock accessed the profile once at school. Several classmates subsequently posted similar profiles, which the principal found demeaning. The principal contacted the police about filing defamation or harassment charges, but no criminal or civil charges were filed. Layshock’s was the least vulgar of the students’ postings, but he was the only student punished. Layshock originally was suspended for 10 days, placed in an alternative education program for the remainder of the year, barred from extracurricular activities, and prohibited from participating in the school’s graduation ceremony, but these disciplinary actions, except for the suspension, were rescinded in exchange for the parents withdrawing their motion for a preliminary injunction. Layshock and his parents challenged the suspension, and the district court granted summary judgment to the Layshocks. The Third Circuit panel affirmed in February, 2010. Applying the disruption standard established in Tinker v. Des Moines Independent School District (503 U.S. 503 (1969)), the appellate panel agreed with the district court that Layshock could not be punished for posting the parody because it did not trigger a substantial disruption of the educational process.
The full Third Circuit Court of Appeals vacated the panel ruling and reheard this case along with J.S. in June 2010 and recently again affirmed the district court’s grant of summary judgment to Layshock on his First Amendment claim. Acknowledging that the parody was not disruptive and thus not excluded from constitutional protection under Tinker, the school district contended that Layshock’s expression was lewd and vulgar, which is not constitutionally protected under the Supreme Court’s ruling in Bethel School District v. Fraser (478 U.S. 675 (1986)). However, the Third Circuit declined to apply Fraser to off-campus lewd and vulgar speech, reasoning that Fraser applies only to student expression occurring at school. Applying Tinker instead, the Third Circuit required the expression to be linked to a school disruption to justify disciplinary action. The court seemed to rely heavily on an earlier Second Circuit decision, Thomas v. Board of Education (607 F.2d 1043 (2d Cir. 1979)), in which the appeals court struck down disciplinary action against students for off-campus distribution of a satirical magazine with some vulgar language as there was no evidence of an adverse impact on the school. The only connection with the school was that students had done some work on the publication in school after hours and stored copies of the publication in a classroom closet. The Third Circuit found the relationship between Layshock’s conduct and the school to be far less than the students’ connection to the school in Thomas. The court concluded that “it would be an unseemly and dangerous precedent to allow the state, in the guise of school authorities , to reach into a child’s home and control his/her actions there to the same extent that it can control” conduct in school-sponsored activities (p. *28). The Third Circuit reasoned that in cases where disciplinary action has been allowed, students’ Internet expression has caused a substantial disruption of the school.
[B]J.S’s First Amendment Claim[/B]
In the second case, two eighth grade female students were suspended for posting on MySpace a parody of their principal created on the weekend at home. These students also used the principal’s picture from the school’s website. The principal was depicted as a sex addict and pedophile who enjoyed “hitting on students and their parents” among other things (p. *4). J.S. originally made the profile public but then limited it to about 20 friends, and no students viewed the profile at school because MySpace was blocked on school computers. The principal was upset and threatened legal action against the families, but after contacting the police he did not file charges. J.S. and her friend were suspended and barred from school functions for 10 days for posting the profile. School authorities asserted that the profile caused a disruption at school (e.g., teachers having to quiet their classes, staff having to alter their schedules to address the issue, students decorating J.S.’s locker when she returned from her suspension).
J.S. and her parents brought suit, and the district court granted the school district’s summary judgment motion on all claims. The court specifically noted that Tinker’s disruption standard did not govern this case because there was no substantial disruption at school. However, the court reasoned that the students could be disciplined under Tinker for expression invading the rights of others, specifically the principal’s rights in this case. Moreover, the court found the vulgar and offensive expression to be unprotected based on Fraser. A divided Third Circuit panel affirmed the district court’s judgment for the school district, concluding that although the incidents of alleged disruption were unpersuasive, school authorities could reasonably forecast a future disruption from the continued posting of the profile.
On the substantive First Amendment question, the Third Circuit en banc by an eight-to-six vote reversed the district court’s grant of summary judgment to the school district, finding a violation of the student’s expression rights. The appeals court relied on the Tinker disruption standard, and in contrast to the appellate panel, the full Third Circuit was hesitant to allow an assessment of possible future disruption to justify disciplinary action against J.S. The court noted that under Tinker, the mere apprehension or fear of disruption was not sufficient to curtail students’ right to silently protest governmental policies by wearing black armbands. The full Third Circuit reasoned that there was no way to know that a disruption would have resulted if the principal had not acted swiftly against the students. As in Layshock, the en banc Third Circuit in J.S. held that Fraser does not authorize schools to punish off-campus lewd and vulgar expression and further held that student expression interfering with the rights of others cannot be curtailed under Tinker unless linked to a school disruption.
[B]Other Claims[/B]
The Third Circuit en banc found the parodies in both cases so outrageous that no one would believe that they were serious. However, the appeals court affirmed the courts below in rejecting the parents’ Fourteenth Amendment claims that the schools’ imposition of discipline for off-campus expression interfered with their liberty rights to control the upbringing of their children. The schools’ actions did not force or prevent the parents from disciplining their children. Also, the Third Circuit did not find the schools’ policies pertaining to the use of technology to be unconstitutionally vague or overbroad.
In both cases, there were concurring opinions. Two justices wrote separately in Layshock to emphasize that Tinker’s disruption standard does apply to students’ off-campus speech that disrupts the school. Conversely, four judges signed a concurrence in J.S., contending that Tinker does not apply to off-campus expression at all. There was no dissent in Layshock, but 6 of the 14 judges dissented in J.S., arguing that school authorities produced sufficient evidence of a school disruption to satisfy Tinker and justify the discipline imposed on J.S. for her off-campus expression.
[B]Implications[/B]
These recent Third Circuit decisions represent a win for students in terms of constitutional protection of their off-campus electronic expression. Also, the court made the most definitive statement to date confining the application of Fraser to expression that occurs at school. While endorsing Tinker’s disruption standard to govern students’ off-campus expression, the Third Circuit judges were not in agreement on the reach of Tinker in this regard. It remains to be seen whether other courts will follow a majority of the Third Circuit in equating off-campus creation and distribution of print material that was at issue in Thomas to off-campus Internet expression that potentially reaches the entire student body.
The Third Circuit distinguished these two cases from the recent Second Circuit opinion involving disciplinary action against a student for her vulgar blog entries from home that school personnel reasonably could forecast would be disruptive; the court found school authorities immune from liability for their actions in this unsettled area of law (Doninger v Schwartz, 2011 U.S. App. LEXIS 8441, 2d Cir., April 25, 2001). The Third Circuit reasoned in part that the student’s disqualification to run for class office in Doninger was a less significant punishment than the suspensions in Layshock and J.S., a conclusion some might question. The Third Circuit also considered the student’s vulgar urging of classmates to criticize school authorities in Doninger to be more detrimental to the school than the posting of fictitious parodies on MySpace.
The Third Circuit’s endorsement of students’ off-campus electronic expression rights may encourage additional harassment and defamation suits initiated by students and school personnel to challenge demeaning and vulgar student Internet expression. Also, public schools may be motivated to strengthen their Internet acceptable use policies and to become more assertive in reaching out to parents regarding the potential negative impact of their children’s harmful expression via social networks. And there undoubtedly will be more First Amendment challenges to MySpace and Facebook postings, with a range of possible judicial opinions. Some courts may follow the Third Circuit in siding with students’ expression rights, whereas others may back the schools or agree with the Second Circuit that the law is too unsettled for liability to be assessed against school authorities. As technology becomes increasingly integrated into daily life, clear guidance on the legality of electronic expression is needed, so it seems likely that the Supreme Court eventually will have to render an opinion on this volatile topic.
Monday, March 28, 2011
Sexting- A girls nude photo and altered lives
http://www.nytimes.com/2011/03/27/us/27sexting.html?_r=1&pagewanted=1&ref=homepage&src=me
Tuesday, March 1, 2011
School interviews on sexual abuse. Interesting case!
17218 17218
« High Court Declines Student Speech Case | Main
Justices Weigh School Interviews on Sex Abuse
By Mark Walsh on March 1, 2011 12:57 PM | No comments | No recommendations
Tweet The U.S. Supreme Court today took up what potentially could be a major test involving the rights of children when interacting with the police and other government investigators in schools.
But in the case over whether school interviews of children by investigators constitute unreasonable "seizures" under the Fourth Amendment, the arguments today quickly stumbled over procedural issues.
"It just seems like the whole case has evaporated," Justice Ruth Bader Ginsburg told Oregon Attorney General John R. Kroger early in the arguments in Camreta v. Greene (Case No. 09-1454). She was referring to the fact that the child in the case, identified as S.G., has not sought money damages from the two investigators who were found to have violated her rights.
The justices spent much of the hour debating whether the appeal presented a live case or controversy, as required by federal law. By the end, the court seemed inclined to throw out the appeal or set aside a federal appeals court ruling which had held that child-abuse investigators must have a court order or parental permission to interview a child at school about potential sex abuse at home.
Kroger said setting aside the ruling by a panel of the U.S. Court of Appeals for the 9th Circuit, in San Francisco, would be acceptable since it would wipe the warrant or parent consent requirement off the books.
"Child-protective workers face an enormous burden to acquire a warrant before even talking to the child," Kroger said.
The Obama administration was the state's ally before the high court, with Acting Principal Deputy Solicitor General Leondra R. Kruger urging the justices to "correct the mistake the 9th Circuit made in this case."
"What we have is a decision that changes the legal landscape for child-protective workers who are doing their best to protect children," Kruger said.
She also said that wiping out the 9th Circuit decision would be acceptable, although that would put up a roadblock to the development of clear legal rules that could guide investigators.
Carolyn A. Kubitschek, the lawyer representing S.G. and her mother, said several times today that overly zealous child-abuse investigations could be harmful to children.
The state's position is that "there are no limits, no constraints" on what investigators could do in interviewing a child in school, Kubitschek said.
In the case from Bend, Ore., 9-year-old S.G. was pulled from her classroom one day in 2003 and taken to a school office, where she was interviewed by a state child-protective-services caseworker and a deputy sheriff.
The authorities suspected the girl was being sexually abused at home. After lengthy questioning, the girl told the investigators that she had been touched inappropriately by her father. The girl and her sister were briefly removed from their home, but criminal charges against their father were later dismissed. The father did accept a plea agreement over abuse charges involving another child.
S.G.'s mother sued not only the investigators who questioned her daughter, but also the Bend-La Pine school district and the school counselor who had removed the girl from class. The mother says in court papers that only after two hours of denying any abuse did S.G. tell the investigators what the girl believed they wanted to hear—that her father had touched her improperly. The school district was dismissed as a defendant in earlier proceedings.
The justices today eventually did get around to exploring the merits of in-school interviews of potential child-abuse victims.
Justice Antonin Scalia wondered, only half-seriously, whether faced with hurdles over removing schoolchildren to a private room to be interviewed, they would be forced to sidle up alongside them in school hallways to inquire about abuse.
Justice Stephen G. Breyer asked whether it constituted a "seizure" under the Fourth Amendment when students were confined to class by school officials for misbehavior.
Kubitschek said most interactions between school personnel and students (as opposed to state investigators) would be governed by cases that give school authorities wide disciplinary latitude.
There seemed to be little sympathy on the court for the idea that the 9th Circuit was right on the merits and that such child-abuse interviews would require a search warrant or parental permission.
"It's hard to swallow that if a child is asked [in circumstances similar to this case] and says she is being abused, that it is unreasonable" for state investigators to take the next steps in an investigation, Justice Sonia Sotomayor said.
A decision in the case is expected by June. On March 23, the court will take up another case involving the police and schools. In J.D.B. v. North Carolina (No. 09-11121), the justices will consider whether a student interviewed at school about suspected neighborhood thefts should have been given a Miranda warning.
« High Court Declines Student Speech Case | Main
Justices Weigh School Interviews on Sex Abuse
By Mark Walsh on March 1, 2011 12:57 PM | No comments | No recommendations
Tweet The U.S. Supreme Court today took up what potentially could be a major test involving the rights of children when interacting with the police and other government investigators in schools.
But in the case over whether school interviews of children by investigators constitute unreasonable "seizures" under the Fourth Amendment, the arguments today quickly stumbled over procedural issues.
"It just seems like the whole case has evaporated," Justice Ruth Bader Ginsburg told Oregon Attorney General John R. Kroger early in the arguments in Camreta v. Greene (Case No. 09-1454). She was referring to the fact that the child in the case, identified as S.G., has not sought money damages from the two investigators who were found to have violated her rights.
The justices spent much of the hour debating whether the appeal presented a live case or controversy, as required by federal law. By the end, the court seemed inclined to throw out the appeal or set aside a federal appeals court ruling which had held that child-abuse investigators must have a court order or parental permission to interview a child at school about potential sex abuse at home.
Kroger said setting aside the ruling by a panel of the U.S. Court of Appeals for the 9th Circuit, in San Francisco, would be acceptable since it would wipe the warrant or parent consent requirement off the books.
"Child-protective workers face an enormous burden to acquire a warrant before even talking to the child," Kroger said.
The Obama administration was the state's ally before the high court, with Acting Principal Deputy Solicitor General Leondra R. Kruger urging the justices to "correct the mistake the 9th Circuit made in this case."
"What we have is a decision that changes the legal landscape for child-protective workers who are doing their best to protect children," Kruger said.
She also said that wiping out the 9th Circuit decision would be acceptable, although that would put up a roadblock to the development of clear legal rules that could guide investigators.
Carolyn A. Kubitschek, the lawyer representing S.G. and her mother, said several times today that overly zealous child-abuse investigations could be harmful to children.
The state's position is that "there are no limits, no constraints" on what investigators could do in interviewing a child in school, Kubitschek said.
In the case from Bend, Ore., 9-year-old S.G. was pulled from her classroom one day in 2003 and taken to a school office, where she was interviewed by a state child-protective-services caseworker and a deputy sheriff.
The authorities suspected the girl was being sexually abused at home. After lengthy questioning, the girl told the investigators that she had been touched inappropriately by her father. The girl and her sister were briefly removed from their home, but criminal charges against their father were later dismissed. The father did accept a plea agreement over abuse charges involving another child.
S.G.'s mother sued not only the investigators who questioned her daughter, but also the Bend-La Pine school district and the school counselor who had removed the girl from class. The mother says in court papers that only after two hours of denying any abuse did S.G. tell the investigators what the girl believed they wanted to hear—that her father had touched her improperly. The school district was dismissed as a defendant in earlier proceedings.
The justices today eventually did get around to exploring the merits of in-school interviews of potential child-abuse victims.
Justice Antonin Scalia wondered, only half-seriously, whether faced with hurdles over removing schoolchildren to a private room to be interviewed, they would be forced to sidle up alongside them in school hallways to inquire about abuse.
Justice Stephen G. Breyer asked whether it constituted a "seizure" under the Fourth Amendment when students were confined to class by school officials for misbehavior.
Kubitschek said most interactions between school personnel and students (as opposed to state investigators) would be governed by cases that give school authorities wide disciplinary latitude.
There seemed to be little sympathy on the court for the idea that the 9th Circuit was right on the merits and that such child-abuse interviews would require a search warrant or parental permission.
"It's hard to swallow that if a child is asked [in circumstances similar to this case] and says she is being abused, that it is unreasonable" for state investigators to take the next steps in an investigation, Justice Sonia Sotomayor said.
A decision in the case is expected by June. On March 23, the court will take up another case involving the police and schools. In J.D.B. v. North Carolina (No. 09-11121), the justices will consider whether a student interviewed at school about suspected neighborhood thefts should have been given a Miranda warning.
Wednesday, February 16, 2011
Saturday, February 5, 2011
Schools Tackle Legal Twists and Turns of Cyberbullying
http://www.edweek.org/dd/articles/2011/02/09/02cyberbullying.h04.html
Schools should pull plug on cyberbullies, expert says (Omaha World Herald Reports)
http://omaha.com/article/20110122/NEWS01/701229859
http://omaha.com/article/20110122/NEWS01/701229855
http://omaha.com/article/20110122/NEWS01/701229855
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