Mahanoy Area School Dist. v. B. L., 594 U.S. 180

Background

B.L., a high‑school student, posted two vulgar Snapchat images off campus on a weekend after failing to make varsity cheer; posts went to her ~250 "friends." Screenshots spread and some teammates were upset.
Cheer coaches suspended B.L. from the junior varsity cheer squad for the coming year for profanity directed at a school activity. School officials upheld the suspension.
B.L. sued, and the District Court enjoined the suspension and granted summary judgment under Tinker, finding no substantial disruption. The Third Circuit affirmed; the panel majority thought Tinker did not apply off campus.
Supreme Court held schools may sometimes regulate off‑campus student speech, but their special leeway is diminished off campus; applying that framework, the Court found the punishment here violated the First Amendment.
The Court identified examples where off‑campus regulation might be justified (serious bullying/harassment, true threats, speech during school‑mandated or school‑sponsored activities including remote learning, breaches of school security), but declined a broad categorical rule and emphasized context.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Tinker apply to off‑campus student speech?	Tinker governs; school cannot punish absent substantial disruption.	Tinker applies only on campus or to speech bearing the school's imprimatur.	Schools may regulate some off‑campus speech, but Tinker's special deference is often diminished off campus; here Tinker's protection controls and school violated B.L.'s rights.
Were B.L.'s Snapchats protected speech?	Protected pure speech/criticism, not fighting words or obscene.	Profanity directed at a school activity is punishable (school morals/order).	Protected: crude criticism of school/team; not outside First Amendment protection.
Did school interests (manners, disruption, team cohesion) justify discipline?	Interests weak because speech was off campus, private circle, minimal disruption evidence.	School must teach manners and preserve team cohesion; posts upset students.	Insufficient: record showed only brief class talk and upset teammates; Tinker’s substantial‑disruption standard not met.
What is the permissible scope of regulating off‑campus speech?	Off‑campus regulation must be narrow and justified; courts should be skeptical.	Schools retain authority in many off‑campus circumstances affecting school safety or activities.	Schools may regulate particular categories (e.g., severe bullying/harassment, true threats, speech in school‑sponsored/required activities, breaches of school security), but authority is context‑dependent and generally reduced off campus.

Key Cases Cited

Tinker v. Des Moines Indep. Cmty. Sch. Dist., 393 U.S. 503 (1969) (schools may regulate student speech that substantially disrupts school operations)
Bethel Sch. Dist. No. 403 v. Fraser, 478 U.S. 675 (1986) (schools may discipline lewd or vulgar speech in school settings)
Hazelwood Sch. Dist. v. Kuhlmeier, 484 U.S. 260 (1988) (schools may regulate speech bearing the school’s imprimatur in school‑sponsored publications)
Morse v. Frederick, 551 U.S. 393 (2007) (schools may restrict student speech promoting illegal drug use in certain school contexts)
Cohen v. California, 403 U.S. 15 (1971) (vulgar or offensive expression is protected unless it falls into a recognized exception)
Chaplinsky v. New Hampshire, 315 U.S. 568 (1942) (identifies categories of unprotected speech such as fighting words)
Snyder v. Phelps, 562 U.S. 443 (2011) (First Amendment protects even hurtful speech on matters of public concern)
Brandenburg v. Ohio, 395 U.S. 444 (1969) (protected advocacy unless directed to and likely to incite imminent lawless action)
Texas v. Johnson, 491 U.S. 397 (1989) (offensive expression is not a sufficient ground for suppression)
Agency for Int’l Dev. v. Alliance for Open Soc’y Int’l, Inc., 570 U.S. 205 (2013) (government may not condition benefits in ways that infringe First Amendment rights)