Pratt v. Independent School District No. 831
670 F.2d 771, 64 A.L.R. Fed. 757 (1982)
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Rule of Law:
A public school board's removal of materials from the curriculum violates the First Amendment if the decision is motivated by a desire to suppress ideological or religious viewpoints with which the majority of the board disagrees.
Facts:
- Since 1972, Independent School District No. 831 used a film version of Shirley Jackson's short story 'The Lottery' and a related trailer film in its high school American literature courses.
- During the 1977-1978 school year, a group of parents and citizens raised objections to the films, citing concerns about their perceived violence and negative impact on students' religious and family values.
- Following the district's review policy, an informational meeting was held where teachers defended the films as tools to provoke discussion on themes like blind adherence to tradition.
- A formal 'Committee for Challenged Materials' was convened, which held a public meeting to review the complaints.
- After its review, the Committee recommended retaining the films in the high school curriculum while allowing parents to have their children opt out of viewing them.
- The Independent School District No. 831 school board held a public meeting where it rejected the Committee's recommendation by a 4-3 vote.
- The board then passed a resolution, also by a 4-3 vote, to completely remove both films from the district's curriculum, providing no official reason for its decision at that time.
Procedural Posture:
- Three students sued Independent School District No. 831 in the United States District Court for the District of Minnesota, seeking an injunction to reinstate the films.
- On cross-motions for summary judgment, the district court found the board's removal of the films was unconstitutional because it was based on their 'ideological content' and ordered their reinstatement.
- The district court then allowed the school board to submit evidence of a legitimate, constitutionally permissible reason for its decision.
- The board submitted a resolution claiming the films overemphasized violence, which the district court found was not credible 'cognizable evidence' and affirmed its earlier order.
- The school board, as appellant, appealed the district court's final order to the United States Court of Appeals for the Eighth Circuit.
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Issue:
Does a public school board's decision to remove films from the school curriculum, based on the board's objections to the films' ideological and religious content, violate the students' First Amendment right to receive information?
Opinions:
Majority - Heaney, Circuit Judge
Yes. A school board's decision to remove films from the curriculum violates the students' First Amendment rights when the action is based on the board's disagreement with the ideological and religious content of the material. While school boards have substantial discretion over curriculum, this power is not absolute and is limited by the First Amendment. Students do not 'shed their constitutional rights to freedom of speech or expression at the schoolhouse gate' and have a right to be free from official actions intended to suppress ideas. The court found that the plaintiffs established a prima facie case that the board removed the films because it objected to their ideological content and purported impact on religious values. The burden then shifted to the board to provide a substantial and reasonable governmental interest for its action. The board's after-the-fact justification—that the films were removed due to an 'undue emphasis on violence and bloodshed'—was found not credible. The court noted the lack of evidence supporting this claim, the absence of any systematic review of violence in other curriculum materials, and the suspicious timing of the justification. Therefore, the removal was an unconstitutional attempt to impose a 'pall of orthodoxy' by suppressing disfavored ideas.
Analysis:
This decision solidifies the principle that a school board's curricular authority is constrained by the First Amendment's prohibition against viewpoint discrimination. It establishes that while boards have broad discretion, their motives for removing educational materials are subject to judicial scrutiny. The ruling creates a significant precedent by applying a burden-shifting framework: once a plaintiff shows that a removal was likely motivated by ideological disagreement, the board must prove a legitimate, non-ideological pedagogical reason for its action. This case reinforces the students' 'right to receive information' and protects the classroom as a marketplace of ideas, limiting the ability of school boards to censor materials based on community or majority objections to controversial themes.
