Brittney Kaye Settle v. Dickson County School Board
1995 WL 261590, 1995 U.S. App. LEXIS 10148, 53 F.3d 152 (1995)
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Rule of Law:
Educators do not violate a student's First Amendment free speech rights by exercising control over the content of student speech in school-sponsored activities, such as classroom assignments, so long as their actions are reasonably related to legitimate pedagogical concerns.
Facts:
- Ninth-grade teacher Dana Ramsey assigned a research paper, requiring students to select their own topic, subject to her approval, based on the criteria that it be 'interesting, researchable and decent.'
- Student Brittney Settle initially signed up to write about 'Drama' but later decided to change her topic.
- Without first obtaining Ramsey's approval as required, Settle submitted an outline for a paper titled 'The Life of Jesus Christ.'
- Ramsey rejected the topic, and a subsequent similar one, giving several reasons: the student's failure to get prior approval, potential difficulty in grading a paper on personal religious beliefs, a concern the student wouldn't need to do actual research on a familiar topic, and a mistaken belief that the law forbids religious topics.
- Settle refused to select another topic for the assignment.
- As a result of not submitting a paper on an approved topic, Settle received a 'zero' for the assignment.
- The school principal, superintendent, and the Dickson County School Board all supported Ramsey's decision.
Procedural Posture:
- Brittney Settle sued her teacher, Dana Ramsey, and school officials in the United States District Court, alleging a violation of her First Amendment free speech rights.
- The defendants filed a motion for summary judgment.
- The district court granted summary judgment for the defendants and dismissed the case.
- Settle, as the appellant, appealed the district court's judgment to the United States Court of Appeals for the Sixth Circuit.
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Issue:
Does a public school teacher violate a student's First Amendment free speech rights by rejecting a proposed topic for a classroom research paper when the teacher's reasons are related to pedagogical concerns?
Opinions:
Majority - Merritt, C.J.
No. A public school teacher does not violate a student's First Amendment free speech rights by rejecting a proposed topic for a classroom research paper because educators have broad discretion to control curriculum and assignments for legitimate pedagogical reasons. Applying the standard from Hazelwood Sch. Dist. v. Kuhlmeier, the court found that a teacher's authority to control speech is even greater in the classroom context than in a school newspaper. So long as the teacher's decision is aimed at learning and is not a pretext for punishing the student's religious or political views, federal courts should not interfere. All of Ramsey's stated reasons, even those that were legally or factually mistaken, fell within her broad discretion to determine curriculum and grades.
Concurring - Batchelder, J.
No. The teacher's actions did not create a constitutional issue because this case is not about restricting a student's expression, but about a teacher's authority to determine what topic is appropriate for a specific assignment. A student has no constitutional right to do something other than the assigned work and still receive credit. While some of the teacher's after-the-fact reasons were unconvincing and her understanding of the law regarding religion in schools was 'dead wrong,' her decision was ultimately an error in pedagogical judgment, not a violation of the student's First Amendment rights. The majority's reliance on Hazelwood and Tinker is misplaced because the facts of this case are not analogous.
Analysis:
This decision extends the 'legitimate pedagogical concerns' standard from Hazelwood, which concerned a school-sponsored newspaper, directly into the academic curriculum of the classroom. It establishes a high bar for students claiming free speech violations in the context of assignments, granting teachers significant deference in making academic judgments. The case distinguishes classroom speech, which is part of the curriculum, from the type of personal, non-disruptive speech protected in Tinker v. Des Moines. The ruling solidifies the principle that the educational mission of a school can justify restrictions on student speech that would not be permissible in other contexts.
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