By Kathryn S. Vander Broek, Evan D. Brown and Steven M. Puiszis

Introduction

The internet is a modern day “Pandora’s Box.” It offers a forum “for a true diversity of political discourse, unique opportunities for cultural development, and myriad avenues of intellectual activity.” 47 U.S.C. § 230(a)(3). The internet can provide meaningful learning opportunities for educators and students unimaginable to earlier generations while also raising a host of concerns for school administrators and parents over its appropriate use. Best practice questions abound concerning how to effectively and productively integrate the internet into the educational setting while simultaneously protecting students.

The internet has brought to the classroom’s door a fundamental paradox confronting our legal and educational systems. Specifically, students using the internet must be protected from inappropriate content or predatory practices, while, at the same time, the First Amendment protects the rights of those who speak, write, or convey ideas or display symbols over the web. One of the internet’s unfortunate byproducts is that in today’s digital era, school administrators are being called upon with increasing frequency to balance the use of internet-based tools that enrich learning against the need to maintain order and a safe learning environment. Balancing these competing concerns is a complex and delicate task.

In its now famous Tinker decision, the United States Supreme Court observed that students do not shed their First Amendment rights when they enter the schoolhouse gates. The Court in Tinker also recognized the need to maintain an effective learning environment. Accordingly, the Court concluded that a student’s First Amendment rights are not without limitation and must be addressed in light of the special characteristics of the school environment. Nonetheless, school officials are not permitted to prohibit or discipline student speech simply because the speech may be provocative or controversial, the officials disagree with the student’s point of view, or the speech is crude, distasteful or unpleasant. Indeed, one of the core functions of the First Amendment is to protect controversial speech. In a series of decisions highlighted in the following sections, the Supreme Court has attempted to balance these competing principles and has broadly outlined when a school lawfully can restrict or discipline a student for speech or expressive activity that would otherwise fall within the ambit of the First Amendment.

The Supreme Court has not yet addressed whether a school district may discipline a student for off-campus speech or for statements made or symbols displayed over the internet from the privacy of a student’s home. A number of lower courts, including the United States Court of Appeals for the Seventh Circuit, have applied the test developed in Tinker when addressing a student’s First Amendment claim involving speech or expressive activities that initially occurred off campus but was later brought to school by students other than the original speaker. However, some courts have concluded that a student’s off-campus speech is entitled to full First Amendment protection even when it finds its way onto school grounds without that student’s assistance.

Students’ online activities raise particularly difficult First Amendment issues for school administrators involving off-campus speech. The internet has expanded schools’ traditional boundaries and blurred when, where and how today’s students can enter the schoolhouse gates. Indeed, there has been a proliferation of web-based educational programs offered online to students of all ages. Has the internet literally moved the schoolhouse gates to students’ home computers? While school administrators may view that to be the case, until the Supreme Court addresses the issue, lower courts and school officials must look for guidance from existing Supreme Court decisions addressing student speech made through fundamentally different media, and First Amendment issues which arose in a markedly different context.

Many courts have been slow to focus on the unique characteristics of the internet which distinguish it from traditional forms of communication. Several traditional modes of communication, such as the print and broadcast media, are heavily regulated and expensive to use. Many individuals lack the resources necessary to use these forums. On the other hand, the internet is both easy and inexpensive to use. Additionally, one of the more attractive features of the web is that it permits the free and unfettered discussion of issues, with practically no regulation or oversight. See, e.g., 47 U.S.C. § 230(a)(4) (noting that the internet has flourished “with a minimum of government regulation”). The spoken or printed word is capable of reaching a finite and limited audience. Information posted on the internet can instantaneously reach a far larger audience potentially anywhere in the world. Moreover, social networking sites and web-based interactive services encourage the development of affinity groups sharing common interests. Messages can be easily conveyed to persons sharing the same interests or points of view. Anonymity is another feature of the internet which makes it a preferred mode of communication for many who otherwise may be unwilling to express their views on controversial subject matters. These features make the internet a highly popular and effective means of communicating ideas and information. However, these same features also make negative comments far more damaging, and anonymous messages or threats far more menacing, when made over the internet. 

A number of lower courts, while sympathetic to school districts’ need to maintain a safe and orderly learning environment, nevertheless have enjoined student discipline for internet-related speech or statements made on social networking websites from the privacy of the student’s home. In several instances, these courts have concluded that the speech did not involve a “true threat,” was not “lewd” or that the school’s concerns over a potential disruption were overblown. While a few decisions can be explained by a failure of proof or by disagreement over whether the test for determining if a statement qualifies as a “true threat” should be objectively viewed from the perspective of the person making or receiving the statement, the reasoning of various decisions is difficult to reconcile. These decisions however, clearly demonstrate that school officials must carefully address their response to off-campus or internet- based student speech. Internet-based, off-campus speech is an emerging area of the law producing decisions that are highly fact specific. However, a few general principles can be gleaned from these lower court decisions, which do bear mentioning.

First, a school district’s position is the strongest when it can demonstrate that a student’s statement or posting communicated what a reasonable person would view to be a true threat. As explained below, “true threats” are not protected speech. In the Seventh Circuit, they are objectively reviewed from the perspective of the person who received the threat. 

Second, to the extent that a school district can establish that a student’s internet posting or speech was brought to school, it should do so. Courts which have enjoined a district’s disciplinary decisions have made a point of mentioning the lack of any nexus between the student’s speech and the school. Off-campus speech can find its way to school either by other students bringing it with them, or electronically when it is viewed online at school. The disruption is the same, irrespective of the format which the speech takes at school. See, e.g., Wilson v. Hinsdale Elementary School 181, 349 Ill. App. 3d 243, 810 N.E.2d 637 (2d Dist. 2004) (upholding a 50-day suspension of a student who wrote, sang and burned to a CD a song that said he was “gonna kill” his pregnant teacher’s baby). In Wilson, the student gave two copies of the CD to other students, who brought the CD to school and played it for yet other students in the school’s computer lab. What matters under Tinker is the degree of disruption which the student’s speech causes, and a district’s ability to prove that disruption should its disciplinary decision be challenged.

Third, school districts have great leeway in regulating the use of their computers and the internet at school. The ability of a district to establish that a student’s offensive speech was accessed (or created in whole or in part) through the use of school computers or the school’s computer network, which in turn violated the district’s policies on computer and internet use, improves the likelihood that a court will uphold the discipline.

Fourth, the more outrageous or potentially dangerous the speech appears from an objective point of view, and/or the more actual or potential school disruption which can be demonstrated, the better the chances that the discipline will be upheld. While courts may not be overly sympathetic to an administrator’s reaction to a boorish or disrespectful parody, it will view threats of violence or defamatory statements in a far more serious light. School districts should be prepared to present evidence concerning: the emotional impact which a threat or posting had on its recipient, be it a teacher or a student; the recipient’s ability to effectively function in the school environment thereafter; the amount of administrative time and expense spent in attempting to resolve the problem; and the amount of classroom or instructional time lost as a result. Remember, judges are only human, and they invariably will take a harder look at discipline that seems out of proportion or an overreaction to a student’s speech.

Fifth, students do not enjoy a right to participate in extracurricular activities. To the extent that the discipline involves a restriction on participation in extracurricular activities, it is more likely to be upheld if challenged.

Finally, the younger the student involved, the more discretion will be afforded a district. In fact, students have to be 13 or older to register on MySpace or Facebook under those websites’ respective “terms of use.”

A school district’s policies should be clearly spelled out on these issues. Policies which fail to provide adequate warning that certain conduct is prohibited or which fail to contain adequately defined standards to prevent their arbitrary enforcement can be challenged on vagueness or overbreadth grounds under the First Amendment. Chicago v. Morales, 527 U.S. 41, 56 (1999). For example, a student code of conduct which permitted discipline for any behavior judged by school officials “to be inappropriate in a school setting” was held unconstitutionally vague in Coy v. Board of Education of North Canton City Schools, 205 F. Supp 2d 791 (N.D. Ohio 2002). Importantly, a school district should carefully consider all of its disciplinary options when addressing the appropriate course for responding to a student’s online activities.

MySpace has made available on its website: “The Official School Administrator’s Guide to Understanding MySpace and Resolving Social Networking Issues.” It is a “must read” for all school administrators and provides instructions on how to contact MySpace and what information should be provided to the company in order to remove a false or offensive profile. It also advises as to what to do when a district learns of an underage user, “cyberbullying” or that threats of violence have been posted on a MySpace account. Go to creative.myspace.com/cms/SafetySite/documents/SchoolAdministratorsGuide.pdf to obtain a copy of the Guide. Many other social networking sites have similar policies or practices which should be investigated as appropriate in the course of responding to complaints.

In order to identify and meaningfully evaluate the kinds of legal issues that arise online, it is also important to have a basic understanding of the dynamics of the modern web. These dynamics are shaped by the technological and cultural context in which content is distributed on the web. Much of the activity on the web today involves the creation and consumption of “social media.” This term broadly describes the various ways internet users interact with one another online, and comprises such activities as creating and commenting on blogs, uploading and sharing “user-generated content” such as video and photos, and communicating with “friends” through social networking sites such as MySpace or Facebook. Typically, when new members join a social networking site, they design an online profile page, which allows them to communicate with other members through e-mail, Instant Messaging (IM) or electronic bulletin board postings. A member’s online profile can be open to all or access can be limited only to “friends.” New profiles for MySpace members who are under 18 are automatically defaulted to private.

Social Media and the First Amendment

Categories of Speech That are not Protected by the First Amendment
There are certain types of speech for which the First Amendment offers no protection, several of which are outlined below. This means students can be disciplined without running afoul of the First Amendment for their expressive activities if they fall within one of the following categories:

“True Threats” Are Not Protected Speech
Watts vs. United States, 394 U.S. 705, 707-08 (1969) (per curiam)

Petitioner in Watts participated in a public rally against police brutality. In a discussion group, he complained about his draft classification and having to report for a military physical and stated: “If they ever make me carry a rifle, the first man I want to get in my sights is L.B.J.” The Supreme Court in Watts held that petitioner’s statement was “political hyperbole” and not a “true threat.” Therefore, his statement was protected under the First Amendment and he could not be prosecuted for threatening the President.

True threats “encompass those statements where the speaker means to communicate a serious expression of an intent to commit an act of unlawful violence to a particular individual or group of individuals.” Virginia v. Black, 538 U.S. 343, 359 (2003).  Whether a student “intended to communicate a potential threat is a threshold issue, and a finding of no intent to communicate obviates the need to assess whether the speech constitutes a ‘true threat.’” Porter v. Ascension Parish School Bd., 393 F.3d 608, 617 (5th Cir. 2004). In the Seventh Circuit, “[t]he test for whether a statement is a threat is an objective one; it is not what the [speaker] intended but whether the recipient could reasonably have regarded the [speaker’s] statement as a threat.” United States v. Schneider, 910 F.2d 1569, 1570 (7th Cir. 1990).

“Fighting Words” are not Protected Speech
Chaplinsky v. New Hampshire, 315 U.S. 568 (1942)

In Chaplinski, a Jehovah’s Witness called a governmental official “a God dammed racketeer” and “a dammed Fascist.” The Supreme Court had little difficulty concluding that those statements were not protected speech under the First Amendment.

Speech That Incites Others to “Imminent Lawless Action” is not Protected
Brandenburg v. Ohio, 395 U.S. 444, 447-49 (1969)

Brandenburg involved a criminal conviction for certain racist and anti-Semitic remarks made at a Ku Klux Klan rally calling for “revengeance.” In overturning that conviction, the Supreme Court held that the First Amendment protects the advocacy of illegal or unlawful action unless it “is directed to inciting or producing imminent lawless action and is likely to incite or produce such action.”

Obscenity Is Not Protected Speech
Miller v. California, 413 U.S. 15, 24 (1973)

Obscene speech has long been held to fall outside the purview of the First Amendment. For years the Supreme Court struggled to define obscenity in a way that did not impermissibly burden protected speech. In Miller, the Court settled on a three-part test for determining if material is obscene and thus unprotected: “(a) whether ‘the average person applying contemporary community standards’ would find that the work, taken as a whole, appeals to the prurient interest; (b) whether the work depicts or describes in a patently offensive way, sexual conduct specifically defined by the applicable state law; and (c) whether the work, taken as a whole, lacks serious literary, artistic, political or scientific value.”

Supreme Court’s First Amendment Decisions Involving Student Speech

Even when students engage in expressive activities that are protected by the First Amendment, they still may be lawfully disciplined under the following circumstances:

Schools May Restrict or Discipline Student Speech When They Have Reason to Believe It Will Materially Disrupt Classroom Work, Substantially Interfere With the Educational Environment or Invade the Rights of Others
Tinker vs. Des Moines Independent Community School Dist., 393 U.S. 503 (1969).

In Tinker, students wore black armbands in silent protest of the Vietnam War and were suspended until they returned to school without the armbands. The Supreme Court in Tinker noted that no material disruption had occurred at the school and observed that the district had failed to present any facts that might reasonably have led school officials to predict that a substantial disruption of school activities was likely to occur. Thus, the Court held that the imposition of student discipline under those circumstances violated the students’ First Amendment rights.

The Supreme Court explained that its “substantial disruption” test should be applied to conduct by students that occur, “in class or out of it, which for any reason - whether it stems from time, place, or type of behavior” materially disrupts classwork, involves substantial disorder or invades another’s rights. However, even under Tinker, a student’s First Amendment rights cannot be restricted merely because school administrators wish to avoid a controversy or when the restriction is based on an unsubstantiated fear of disruption. While there must be more than some mild distraction or curiosity created by the speech, complete chaos is not required to meet Tinker’s test.

Schools May Prohibit or Discipline Students for Vulgar or Lewd Speech That Occurs at School
Bethel School District No. 403 vs. Fraser, 478 U.S. 675 (1986).

Bethel involved statements made at a high school assembly by a student who nominated a fellow classmate for elective office. That nominating speech was riddled with sexual innuendos about his fellow classmates, including that he was “firm in his pants” and if elected, would take “take it to the climax.” Bethel rejected the student’s argument that his suspension violated the First Amendment, and held that student speech which is lewd or plainly offensive is not protected by the First Amendment.

The Supreme Court in Bethel recognized that one of the purposes of public education is to “prepare pupils for citizenship in the Republic. . . . It must inculcate the habits and manners of civility.” Note, however, that Bethel addressed speech which occurred on school property, at a school assembly, and did not involve off-campus speech.

Schools Do Not Violate the First Amendment by Exercising Editorial Control Over the Content of Student Speech in School-Sponsored Activities So Long As Their Actions Are Related to “Legitimate Pedagogical Concerns”
Hazelwood School District v. Kuhlmeier, 484 U.S. 260 (1988).

Hazelwood involved a high school principal’s removal of articles in a school newspaper dealing with teen pregnancy and the impact of divorce on teenagers. The newspaper was produced as part of the school’s journalism class. The Supreme Court in Hazelwood rejected the student’s claim that the principal’s editorial censorship of the school paper violated the First Amendment.

Schools Can Discipline Students or Prohibit Student Speech Which Advocates Drug Use
Morse v. Frederick, 127 S. Ct. 2618 (2007).

In Morse, a school district organized a gathering of students to view the Olympic torch passing the street on which the school was located. There, plaintiff and several other students unfurled a banner bearing the phrase, “BONG HiTS 4 Jesus.” The student was suspended for 10 days and challenged his suspension by arguing that the case involved off-campus speech. The Supreme Court rejected that argument because the event was school-sponsored and school-approved, teachers were present, and plaintiff directed the banner towards his school, which was plainly visible to most students.

Morse is remarkable not for its holding, but for the Court’s discussion of its prior decisions involving student speech and the efforts made to limit the opinion’s reach. The Court in Morse held that Hazelwood was inapplicable because the student banner did not bear “the school’s imprimatur” like the school newspaper in Hazelwood. Several justices explained that Morse provides no support for any restriction of student speech that arguably comments on any political or social issue. The Court also refused to endorse the proposition argued for by the district that “public school officials [may] censor any student’s speech that interferes with a school’s ‘educational mission.’”

Seventh Circuit’s First Amendment Decisions on Student Speech

The Seventh Circuit recently concluded that a preliminary injunction should be entered against a school district that prevented a high school student from wearing a T-shirt bearing the phrase: “Be Happy Not Gay.” The court concluded that it was highly speculative that allowing a student to wear that T-shirt would result in a substantial disruption of school activities. In reviewing the Supreme Court’s decisions on “substantial disruption,” the Seventh Circuit explained:

From Morse and Fraser, we infer that if there is reason to think that a particular type of student speech will lead to a decline in students’ test scores, an upsurge in truancy, or the symptoms of a sick school – symptoms therefore of substantial disruption – the school can forbid the speech.

Nuxoll v. Indian Prairie Sch. Dist. #204, 523 F.3d 668, 674 (7th Cir. 2008). The court in Nuxoll also reaffirmed that the younger the student, the more leeway a school district will be granted in regulating student speech. In Baxter v. Vigo County School Corp., 26 F.3d 728 (7th Cir. 1994), the court held that it was not clearly established that a grammar school student enjoyed a First Amendment right to wear expressive t-shirts to school and affirmed the dismissal of plaintiff’s claims for money damages against school administrators based on qualified immunity.

So long as school officials ”have reason to believe” a student’s expression will be disruptive, Tinker’s standard is met. However, school officials still must be ready to present proof of all relevant facts on which their forecast of disruption was based.  See Boucher v. School Bd. of Greenfield, 134 F.3d 821 (7th Cir. 1998) (overturning a preliminary injunction and upholding a high school student’s expulsion for writing an article in an underground school newspaper published off campus explaining how to hack into the school’s computers). In Boucher, the school district presented testimony from computer experts it retained to perform diagnostic testing on the school’s computers and changed all of the passwords mentioned in the student’s article. The diagnostic testing revealed signs of tampering, although the tampering could not be directly tied to the article.

Supreme Court First Amendment Decisions Relating to Employee Speech

The Supreme Court has explained that public employees also do not lose their First Amendment rights simply by virtue of their public employment. A public employee retains a First Amendment right to speak as a private citizen on matters involving a public concern. See, e.g., Pickering v. Board of Educ., 391 U.S. 563, 572 (1968).

Where an employee does not speak as a private citizen or where his or her speech does not address a matter of public concern, the employee can be disciplined without the First Amendment being violated. In Garcetti v. Cebalos, 547 U.S. 410 (2006), the Supreme Court held that where “public employees make statements pursuant to their official duties, the employees are not speaking as citizens for First Amendment purposes, and the Constitution does not insulate their communications from employer discipline.”

Social Media and the Schools

Instructional Considerations

Social Media Affords Teachers Creative Outlets for Imparting Knowledge 
Students and teachers are no different from any other web users in that they stand to benefit from the numerous kinds of tools available to facilitate communication and collaboration. The educational experience can be streamlined, and indeed enhanced, by the use of platforms which make it easier for teachers and students to interact with each other and among themselves. Many of the functions that one sees in the typical social networking site -- like messaging, sharing links and common collaboration "spaces" -- can be used in the school context. Teachers can post assignments and class notes and answer frequently asked questions. Students can send messages to their teachers seeking help on particular issues. One company that has begun to leverage the tools of social media and apply them in the classroom context is Edmodo (www.edmodo.com).

As of 2009-2010 Internet Safety Must be Taught to Students in Grades 3 and Above
In August, 2007 the School Code was amended to afford school districts the opportunity to establish age appropriate curriculum content in the area of internet safety education for grades K-12. The purpose of the education was to “inform and protect students from inappropriate or illegal communications and solicitation and to encourage school districts to provide education about internet threats and risks, including without limitation child predators, fraud, and other dangers.” 105 ILCS 5/27-13.3(a). The overriding legislative concern was use of the internet by sexual predators and deceptive practices that result in harassment, exploitation and physical harm.

Two hours of instruction per year was recommended, to include subjects such as:

• Safe and responsible use of social networking Websites, chat rooms, electronic mail, bulletin boards, instant messaging, and other means of communication on the Internet.
• Recognizing, avoiding, and reporting online solicitations of students, their classmates, and their friends by sexual predators.
• Risks of transmitting personal information on the Internet.
• Recognizing and avoiding unsolicited or deceptive communications received online.
• Recognizing and reporting online harassment and cyber-bullying.
• Reporting illegal activities and communications on the Internet.
• Copyright laws on written materials, photographs, music, and video.

Id. at § 5/27-13.3(c). Starting in the 2009-2010 school year, annual internet safety instruction will be mandatory for grades 3 and higher, and school boards are to determine the scope and duration of the instructional program, with the above topics continuing to be recommended.

Policy Considerations

School Policies Should Address Use of Social Media for Purposes of Bullying or Other Aggressive Conduct
Schools have an obligation to intervene with students whose conduct “puts them at risk for aggressive behavior, including without limitation bullying, as defined in the [discipline] policy.” 105 ILCS 5/10-20.14(d). Bullying policies, moreover, must be updated every two years and filed with the Illinois State Board of Education. 105 ILCS 5/27-23.7(d). To the extent provided, the School Code has identified the following items as being appropriate for inclusion in bullying prevention education, but does not limit a school district’s definition of bullying to these activities: intimidation, student victimization, sexual harassment, and sexual violence. 105 ILCS 5/23.7(b).

• Including “cyber-bullying” in your district’s definition of bullying gives the administration a platform from which to impose appropriate consequences for use of social media to intimidate, harass, threaten or otherwise bully others. Before taking action, you still may need to analyze the nature of the communication(s) to determine if it is protected by First Amendment free speech rights. The failure to incorporate use of the internet or other forms of social media for purposes of bullying in the district’s discipline code, however, may preclude administrators from lawfully imposing disciplinary consequences for its misuse.

Prohibit the Use of Social Media for Purposes of Harassment and/or Discrimination of or by Students and/or Staff
Multiple federal, state and/or local laws prohibit harassment or discrimination based on a protected category, including but not limited to: race, gender, national origin, disability, religion and sexual orientation. These prohibitions apply equally to students and employees who may venture into the use of social media sources for nefarious purposes. 

• Be certain your policies and trainings addressing the prohibition of harassment and discrimination include the use of social blogs or other social media as a prohibited means for engaging in such conduct for which disciplinary action may be taken.

Personal Electronic Devices in Schools

The School Code prohibits student possession of electronic paging devices on school grounds, unless specifically authorized. 105 ILCS 5/10-21.10(b). Policies addressing electronic devices, however, usually extend beyond paging devices to include cell phones, PDAs, digital recorders such as iPods and MP3 players and more. As technology has advanced, many of these devices also are capable of internet or web-based access. This expands the opportunity for students and others to engage in blogging or text messaging, or to visit social networking sites throughout the school day.

• Does your district’s policy limit access to or use of personal cell phones or other electronic devices capable of accessing the internet during some or all of the school day? Consider including misuse of personal electronic devices on school grounds or at school activities in violation of the district’s policies prohibiting, for example, bullying, discrimination, or harassment as being grounds for corrective action under the district’s discipline code.

School Supported Internet Access and Usage Policies Provide Another Avenue for Addressing Misuse of Social Media

Most schools have policies outlining the terms and conditions under which students and staff may use district provided electronic equipment, networks and internet access. This is done for purposes of promoting appropriate conduct on and use of electronic mediums in the school setting and to meet obligations under federal laws to promote the safety of minors while using internet services to which the school may provide access for instructional purposes.

The Children’s Internet Protection Act specifically requires school districts which receive discounted access to the internet through the E-rate program to have policies in place that address, “the safety and security of minors when using electronic mail, chat rooms, and other forms of direct electronic communications,” among other things. 47 U.S.C. § 245(l). Additionally, these schools must certify that they have in place an internet safety policy protecting minor users from visual depictions of material that is obscene, child pornography or otherwise harmful to minors. 20 U.S.C. § 6777, 47 U.S.C. § 254(h)(5).

The term “harmful to minors” is defined as:

any picture, image, graphic image file, or other visual depiction that:

• taken as a whole and with respect to minors, appeals to a prurient interest in nudity, sex, or excretion;
• depicts, describes, or represents, in a patently offensive way with respect to what is suitable for minors, an actual or simulated sexual act or sexual contact, actual or simulated normal or perverted sexual acts, or a lewd exhibition of the genitals; and
• taken as a whole, lacks serious literary, artistic, political, or scientific value as to minors.

47 U.S.C. § 245(h)(7)(G). Federal or Illinois state legislative efforts to entirely preclude or severely limit access by minors to social networks in libraries and public schools, however, have been unsuccessful.

• Three factors are critical to include in district policies for purposes of ensuring that the district is not unduly hampered in meeting its obligations in the area of monitoring internet use and safety. First, ensure that your district’s policy establishes that the user has no reasonable expectation of privacy in the information contained on or accessed through the district’s electronic equipment or networks, including the internet. Second, reserve the right to monitor use of the district’s electronic equipment and networks, without the consent of the user. Third, limit use of the district’s electronic mediums to educational purposes, aligned with the district’s recognized and approved educational objectives.
• Many districts also incorporate a list of Dos and Don’ts in guidelines regarding use of their computer networks. Another means of ensuring school administrators and boards have