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Mahanoy Area School District v. B.L.

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Supreme Court of the United States
Mahanoy Area School District v. B.L.
Term: 2020
Important Dates
Argument: April 28, 2021
Decided: June 23, 2021
Outcome
Affirmed
Vote
8-1
Majority
Stephen Breyer • Chief Justice John Roberts • Sonia Sotomayor • Elena Kagan • Brett Kavanaugh • Amy Coney Barrett
Concurring
Samuel Alito • Neil Gorsuch
Dissenting
Clarence Thomas

Mahanoy Area School District v. B.L. is a case argued before the Supreme Court of the United States during the court's October 2020-2021 term.

In an 8-1 ruling, the U.S. Supreme Court affirmed the U.S. Court of Appeals for the 3rd Circuit's ruling, holding that while public schools may have a special interest in regulating some off-campus student speech, the special interests offered by the Mahanoy Area School District were not sufficient to overcome B. L.’s interest in free expression in the case. Justice Stephen Breyer delivered the majority opinion of the court. Justice Samuel Alito filed a concurring opinion, joined by Justice Neil Gorsuch. Justice Clarence Thomas filed a dissenting opinion.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: Mahanoy Area School District student B.L. was suspended from the school's cheerleading team after posting a Snapchat snap that the team coaches deemed to be in violation of team and school rules. School officials upheld the coaches' ruling, while stating that B.L. could try out for the team again the following school year. B.L. sued the school in federal district court under Title 42 of the United States Code, claiming that the school had violated her First Amendment rights by attempting to regulate her off-campus speech and discipline her for the speech. The district court ruled in her favor and the 3rd Circuit affirmed the ruling. Click here to learn more about the case's background.
  • The issues: The case concerned Title 42 of the United States Code and whether Tinker v. Des Moines Independent Community School District (1969) applies to students' off-campus speech.
  • The questions presented: "Whether Tinker v. Des Moines Independent Community School District, 393 U.S. 503 (1969), which holds that public school officials may regulate speech that would materially and substantially disrupt the work and discipline of the school, applies to student speech that occurs off campus."[2][3]
  • The outcome: The U.S. Supreme Court affirmed the U.S. Court of Appeals for the 3rd Circuit's ruling.


    • The case came on a writ of certiorari to the United States Court of Appeals for the 3rd Circuit. Click here to review the lower court's opinion.[4]

    Timeline

    The following timeline details key events in this case:

    Background

    At the time of the action in the case, B.L. was a student at Mahanoy Area High School (MAHS). As a rising freshman, she tried out for cheerleading and made the junior varsity team. The next school year, she was again placed on the junior varsity team. That same year, an incoming freshman was placed on the varsity team. On a Saturday at a local store with a friend, B.L. vented her frustration by posting a captioned photo on her Snapchat story.[4][5] One of B.L.'s teammates took a screenshot of the snap and sent it to one of the school's cheerleading coaches. The other coach had already been made aware by other students. The coaches determined that the snap violated team and school rules and removed B.L. from the team. B.L.'s parents appealed to school officials, who ruled that B.L. could try out for the team the next school year and upheld the coaches' decision for that year.[4]

    B.L. sued the school district in the United States District Court for the Middle District of Pennsylvania under Title 42 of the United States Code, arguing that her First Amendment rights had been violated, that the school and team rules at issue were too broad and thus discriminatory, and that they were unconstitutionally vague. B.L. moved for summary judgment and the court granted the motion, holding that B.L.'s off-campus speech was not subject to the school's regulation and was not subject to discipline under Tinker v. Des Moines Independent Community School District (1969) and that the school had violated B.L.'s First Amendment rights. The court awarded B.L. damages and required the school to expunge her disciplinary record.[4]

    The school district appealed the ruling to the U.S. Court of Appeals for the 3rd Circuit. On appeal, the 3rd Circuit affirmed the Middle District of Pennsylvania's ruling, holding that the school had violated B.L.'s First Amendment rights.[4]

    Title 42

    Section 1983 of Title 42 of the United States Code reads:[6]

    “ Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer's judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable. For the purposes of this section, any Act of Congress applicable exclusively to the District of Columbia shall be considered to be a statute of the District of Columbia.[7] ”

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether Tinker v. Des Moines Independent Community School District, 393 U.S. 503 (1969), which holds that public school officials may regulate speech that would materially and substantially disrupt the work and discipline of the school, applies to student speech that occurs off campus.[7] ”


    Oral argument

    Audio

    Audio of oral argument:[8]



    Transcript

    Transcript of oral argument:[9]

    Outcome

    In an 8-1 ruling, the U.S. Supreme Court affirmed the U.S. Court of Appeals for the 3rd Circuit's ruling, holding that while public schools may have a special interest in regulating some off-campus student speech, the special interests offered by the Mahanoy Area School District were not sufficient to overcome B. L.’s interest in free expression in the case. Justice Stephen Breyer delivered the majority opinion of the court. Justice Samuel Alito filed a concurring opinion, joined by Justice Neil Gorsuch. Justice Clarence Thomas filed a dissenting opinion.[1]

    Opinion

    In the court's majority opinion, Justice Stephen Breyer wrote:[1]

    “ A public high school student used, and transmitted to her Snapchat friends, vulgar language and gestures criticizing both the school and the school’s cheerleading team. The student’s speech took place outside of school hours and away from the school’s campus. In response, the school suspended the student for a year from the cheerleading team. We must decide whether the Court of Appeals for the Third Circuit correctly held that the school’s decision violated the First Amendment. Although we do not agree with the reasoning of the Third Circuit panel’s majority, we do agree with its conclusion that the school’s disciplinary action violated the First Amendment.[7] ”
    —Justice Stephen Breyer

    Concurring opinion

    Justice Samuel Alito filed a concurring opinion, joined by Justice Neil Gorsuch.

    In his concurring opinion, Justice Alito wrote:[1]

    “ I join the opinion of the Court but write separately to explain my understanding of the Court’s decision and the framework within which I think cases like this should be analyzed. This is the first case in which we have considered the constitutionality of a public school’s attempt to regulate true off-premises student speech, and therefore it is important that our opinion not be misunderstood.


    ... There are more than 90,000 public school principals in this country and more than 13,000 separate school districts. The overwhelming majority of school administrators, teachers, and coaches are men and women who are deeply dedicated to the best interests of their students, but it is predictable that there will be occasions when some will get carried away, as did the school officials in the case at hand. If today’s decision teaches any lesson, it must be that the regulation of many types of off-premises student speech raises serious First Amendment concerns, and school officials should proceed cautiously before venturing into this territory.[7]

    		”
    —Justice Samuel Alito

    Dissenting opinion

    Justice Clarence Thomas filed a dissenting opinion.

    In his dissent, Justice Thomas wrote:[1]

    “ B.L., a high school student, sent a profanity-laced message to hundreds of people, including classmates and teammates. The message included a picture of B.L. raising her middle finger and captioned “F*** school” and “f*** cheer.” This message was juxtaposed with another, which explained that B.L. was frustrated that she failed to make the varsity cheerleading squad. The cheerleading coach responded by disciplining B. L.


    The Court overrides that decision—without even mentioning the 150 years of history supporting the coach. Using broad brushstrokes, the majority outlines the scope of school authority. When students are on campus, the majority says, schools have authority in loco parentis—that is, as substitutes of parents—to discipline speech and conduct. Off campus, the authority of schools is somewhat less. At that level of generality, I agree. But the majority omits important detail. What authority does a school have when it operates in loco parentis? How much less authority do schools have over off-campus speech and conduct? And how does a court decide if speech is on or off campus?

    Disregarding these important issues, the majority simply posits three vague considerations and reaches an outcome. A more searching review reveals that schools historically could discipline students in circumstances like those presented here. Because the majority does not attempt to explain why we should not apply this historical rule and does not attempt to tether its approach to anything stable, I respectfully dissent.

    ... The Court transparently takes a common-law approach to today’s decision. In effect, it states just one rule: Schools can regulate speech less often when that speech occurs off campus. It then identifies this case as an “example” and “leav[es] for future cases” the job of developing this new common-law doctrine. Ante, at 7–8. But the Court’s foundation is untethered from anything stable, and courts (and schools) will almost certainly be at a loss as to what exactly the Court’s opinion today means.

    Perhaps there are good constitutional reasons to depart from the historical rule, and perhaps this Court and lower courts will identify and explain these reasons in the future. But because the Court does not do so today, and because it reaches the wrong result under the appropriate historical test, I respectfully dissent.[7]

    		”
    —Justice Clarence Thomas

    Text of the opinion

    Read the full opinion here.

    October term 2020-2021

    See also: Supreme Court cases, October term 2020-2021

    The Supreme Court began hearing cases for the term on October 5, 2020. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[10]

    The court issued 67 opinions during its 2020-2021 term. Two cases were decided in one consolidated opinion. Ten cases were decided without argument. Click here for more information on the court's opinions.

    The court agreed to hear 62 cases during its 2020-2021 term. Of those, 12 were originally scheduled for the 2019-2020 term but were delayed due to the coronavirus pandemic. Five cases were removed from the argument calendar.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 U.S. Supreme Court, Mahanoy Area School District v. B.L., decided June 23, 2021
    2. ↑ 2.0 2.1 Supreme Court of the United States, "Mahanoy Area School District v. B.L.: Questions presented," accessed January 11, 2021
    3. ↑ Supreme Court of the United States, "Mahanoy Area School District v. B.L.: Petition for a writ of certiorari," August 28, 2020
    4. ↑ 4.0 4.1 4.2 4.3 4.4 U.S. Court of Appeals for the 3rd Circuit, B.L. v. Mahanoy Area Sch. Dist., decided June 30, 2020
    5. ↑ Snapchat is a social media platform that allows users to send private text, photo, and video messages to other users." Snaps can be viewed only temporarily and "cannot be accessed from the web."
    6. ↑ Castext, "42 U.S.C. § 1983: Section 1983 - Civil action for deprivation of rights" accessed January 11, 2021
    7. ↑ 7.0 7.1 7.2 7.3 7.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    8. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed April 28, 2021
    9. ↑ Supreme Court of the United States, "Oral Argument - Transcript," accessed April 28, 2021
    10. ↑ SupremeCourt.gov, "A Brief Overview of the Supreme Court," accessed April 20, 2015
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