Before and After the Hazelwood Ruling
In the United States, the censorship of school publications is nearly blamed on a 1988 Supreme Court ruling, though the ruling simply codified a practice that was already well established.
In 1983, the principal of Missouri’s Hazelwood East High School removed two pages from the school’s student newspaper, because they featured articles on the topics of teen pregnancy and the impact of parents’ divorce on children. Cathy Kuhlmeier, one of the student editors, decided to fight back, arguing that the principal’s decision met conditions for restraint of the press. While a federal district judge ruled against Kuhlmeier, the Eighth Circuit Court of Appeals ruled in her favor. In 1988, five years after her case was filed, the Supreme Court ultimately ruled 5-3 that public school officials do have the power to censor school newspapers, plays, and other “school-sponsored expressive activities.”
Since 1988, Hazelwood has continued to cast a chill on student journalism across the United States, empowering schools to not only to censor references and depictions of pregnant teens and teen parents but any image, article, or even reference to an event or ideology that seems to be at odds with the school or school district’s policies and positions. For example, since 2020, Hazelwood has consistently been cited to justify the censorship of mere references to Black Lives Matter and student-led protests against anti-gay and anti-transgender legislation in student publications. But it would be misleading to assume Hazelwood is solely responsible for the censorship of school newspapers and yearbooks.
The Hazelwood ruling made it nearly impossible for student journalists to rely on laws that protect other US journalists, but in many respects, Hazelwood simply offered a legal precedent to back up the censorship of school journalists that was already pervasive.
Reading Resistance, Between the Lines
From the Civil Rights movement to the more recent struggle for transgender rights, schools have frequently emerged as the sites where shifting cultural norms and laws are first put to the test. Yet, if you set out to write a history of American culture based on yearbooks alone, however, the most significant political events and movements of the past century would likely never make an appearance.
The silence of school yearbooks on race politics and the fight for racial equality first struck me when I started to look for documentation on the Civil Rights movement in U.S. yearbooks from the 1960s. A survey of hundreds of yearbooks revealed that even those produced at schools in communities at the center of the fight for racial equality rarely touch upon racial politics. One notable exception I discovered was a junior high school yearbook from Harlem’s Wadleigh High School.