Factors Affecting the Degree to which the Student Press of Michigan is Subject
to Prior Review and/or Prior Restraint
A Paper Submitted to the Scholastic Journalism Division
for Presentation at the Annual Convention of
the Association for Education in Journalism and Mass Communication
in Baltimore, Maryland, August 5-8, 1998
Kimberly A. Lauffer, doctoral student
2041-A Weimer Hall
College of Journalism and Communications
University of Florida
Gainesville, Fla. 32611
[log in to unmask]
Factors Affecting the Degree to which the Student Press of Michigan is Subject
to Prior Review and/or Prior Restraint
A 55-item questionnaire was sent to 350 randomly selected high school
publications advisers in Michigan. The response rate was 55 percent after the
third wave. While an adviser's experience was not significantly correlated with
incidence of censorship, an adviser's perception of administration as likely to
censor was. Size of school was significantly correlated with how advisers
perceived administrators' views of prior review as was size of school and
whether that school had an editorial policy regarding student publications.
Factors affecting the degree to which the student press of Michigan is subject
to prior review and/or restraint
The Supreme Court progressively has established more stringent restrictions for
the freedoms of speech and press in the school setting since the 1969 Tinker
v.Des Moines Independent Community School District1 decision, which set the
standard for determining whether students' personal expression within the
confines of a school setting was acceptable. The majority opinion of the Court
stated, "It can hardly be argued that either students or teachers shed their
constitutional rights to freedom of speech or expression at the schoolhouse
Fewer than two decades later, two decisions in the 1980s allowed school boards
and administrators to judge what is appropriate for students to view and hear in
light of their emotional maturity3 and to restrict those curricular materials
and educational activities4 that they deemed inappropriate, "pervasively
vulgar,"5 or "otherwise lacking in 'educational suitability'"6 or those they
thought would undermine the school's educational mission.7 While these
decisions did not necessarily change the Court's view toward constitutionally
guaranteed freedoms within a school setting, they did provide the framework for
the 1988 decision that prompted a reevaluation of the freedoms enjoyed by
The ruling in Hazelwood School District v. Kuhlmeier8 provided the most
sweeping restrictions on student freedom of expression. This ruling gave
educators greater control over school-sponsored student expression, including
school-sanctioned publications, theatrical productions and other expressive
activities.9 Hafen suggested the impact of Hazelwood lies in its limitation of
any student speech that shows inconsistency with the institution's "basic
educational mission."10 Decisions to censor under Hazelwood, according to Hafen,
must satisfy two queries: does the expression run counter to the mission of the
institution, and is there a rational (not necessarily educational) basis for its
removal?11 As Hafen noted, "Hazelwood characterizes the entire category of
student expression within official educational channels or activities as speech
entitled to only minimal judicial protection."12
In light of the near-decade of Hazelwood's influence, a study to determine some
of the factors affecting the rate of prior review and prior restraint of
Michigan's high school presses was undertaken in the spring of 1997, nine years
after the Supreme Court's decision in Hazelwood v. Kuhlmeier (1988)13, which
arguably restricted the freedom of scholastic presses. The given factors
included school size, adviser training, editorial policies, how favorably
advisers perceive administrators' views of prior review to be, and how that
perception affects the actual rate of prior review and/or restraint.
Dating from the 1969 Tinker decision, student publications have been viewed as
forums for student opinion, and as such, have traditionally been free from
censorship by administrative entities. However, with the Hazelwood ruling in
1988, student publications created as part of the school curriculum have been
redefined as "school-sponsored expressive activities"14 that cannot be
considered open forums and as such are no longer subject to the freedoms offered
by Tinker. Many scholars, as well as dissenting Justices Brennan, Marshall, and
Blackmun, find such a restriction on freedom of expression untenable for a
variety of reasons, including the lack of inculcation of critical thinking
skills15 and democratic values16 and the potential financial responsibility that
could be placed on schools for content of student publications.17
Dvorak and Dilts cited several court cases which whittled away at the rights of
both teachers and students within the school environment.18 They noted the
Court's primary concern in all cases, including Hazelwood, seems to be
maintaining order and efficiency in the school commensurate with community
concerns to promote learning. In these cases, the rights of the teacher to
choose methodologies and forms of expression and the rights of the student to
express him- or herself seem to be secondary.
What previous research has found
Eveslage found that restraint of student expression was more common among
advisers with five or fewer years experience and no journalism training.19
Principals and advisers who were most aware of student press rights had
different sources of knowledge. Highly aware principals were more likely to read
about student rights in professional publications. Highly aware advisers were
more likely to gather information about student press rights by attending
professional meetings.20 Eveslage also found that restraint was higher among
principals and advisers who were more aware of student press rights.21
In a study of Kentucky advisers, Dodd found that advisers with more journalism
training were more likely to address controversial topics based on their
knowledge of student press rights and to challenge administrative decisions
about student journalism.22
A 1993 national mail survey of high school journalism educators by Arnold found
that new teachers with two or fewer years of experience, teachers from small
towns and rural areas, and teachers who are not certified in journalism were
most likely to seek assistance from the principal in making decisions about
content. These advisers were also more likely to make changes themselves when
student copy was sensitive, controversial, or critical of school
In terms of what advisers consider censorship, Dickson found that more than 70%
of respondents knowledgeable about scholastic journalism said "an adviser should
read the entire newspaper before publication."24 Only 14.5% said a "good
adviser" should not read the newspaper before publication. When it came to
spelling mistakes, 37.5% said an adviser should make changes only if there
wasn't time to tell the editor, and 25% said the adviser should make corrections
whether or not there was time to tell the editor. However, Dickson also found
that most experts agreed that advisers should not change copy for "inadequate
research" (73.2%), unbalanced reporting (63.7%), taking a non-neutral position
on a controversial political topic (83.7%), or addressing mature subjects
Although Dickson found that a majority of principals had not kept materials
from being printed, nearly all said they would censor certain subjects under
specific circumstances. Objectionable material included vulgar language, sex,
drugs, and student pregnancy.26 Salomone concluded that although other
intervening variables made it impossible to determine whether Hazelwood had,
indeed, increased the amount of administrative censorship; in general, the
larger the school, the more controversy over publications.27 However, Dickson
asserted that "principals in larger schools appear to be more tolerant of open
student expression than are principals in smaller schools."28 Also, Dickson
noted that "advisers may be more likely to show principals such questionable
articles because of the Hazelwood ruling."29
In a 1992 study, Dickson determined that "advisers who had taken more college
journalism courses or who had more advising experience sometimes were more
likely than their less-educated and less-experienced counterparts to use prior
restraint."30 Dickson found that school size affected whether controversial
topics were addressed by the student newspaper.31 He also found that prior
restraint was used infrequently by advisers and principals.32
Editorial policies also may have an effect on acts of prior review and/or
restraint by advisers and administrators. Eveslage found that lack of journalism
training and lack of written policies on appropriate content affected restraint
of student expression.33 Eveslage also found higher reports of restraint among
advisers and principals who were more aware of student press rights.34 Dodd and
Mays found that 48% of Florida high schools surveyed had a written policy while
33% did not; 10% of survey respondents did not know and 9% did not answer the
In summary, advisers with less experience seem to address less controversial
topics and exercise more restraint than more experienced advisers. Additionally,
the size of the school affects the frequency with which controversial topics are
addressed. In terms of what constitutes censorship, many experts do not include
prior review within the definition of censorship. Most experts agreed that
advisers should read student newspapers before publication. More than half said
it was acceptable for advisers to change spelling during the course of prior
review, and that doing so did not constitute censorship. However, for an adviser
to change copy because of inadequate research, unbalanced reporting, non-neutral
political reporting or coverage of mature topics was not considered appropriate
by most experts.
Parameters and procedures of the current study
The general intent of this study was to survey high school publications
advisers about their advising experience, their likelihood of censorship, and
their perception of how favorably their administrators viewed censorship
activities. Advisers were chosen because they would be able to provide
information about their own views toward and acts of prior review and restraint.
Additionally, advisers also could respond regarding their perceptions of their
administrators' views toward and acts of prior review and prior restraint.
Hypotheses, research questions and operationalized terms
The following hypotheses and research questions were generated by a review of
H1) More experienced advisers will exercise prior review
and/or prior restraint less frequently.
H2) An adviser who perceives administration as more
favorable toward censorship will be more likely to exercise
Q1) How likely to censor student publications are
Michigan advisers and administrators?
Q2) Does size of school affect the amount of censorship,
and if it does, what is the relationship and what are the given
Q3) Does size of school affect whether that school has
an editorial policy regarding student publications?
For the purposes of this study, censorship was defined as prior restraint or
prior review. Prior restraint was defined in this study as "removing items in a
publication prior to publication" or "removing questionable items prior to
publication," and prior review was defined as "reviewing a publication prior to
publication." Although these definitions differ somewhat from Dickson's, they
were derived from consultations with members of the Michigan Interscholastic
Press Association. While true censorship is often viewed as removal (prior
restraint), some say that expecting the publisher to review copy prior to
publication is tantamount to censorship, as it may affect the type or depth of
the reporting, especially in high schools, where criticism of school officials
could result in not only removal of the copy but sanctions levied against the
For hypothesis one, advisers' experience was measured by years of teaching,
length of time advising, and continuing education or training in journalism.
Advisers were asked in open-ended questions to indicate the number of years they
had been advising student publications and the number of years they had been
teaching. In another question, advisers were asked what sort of continuing
training they had received in journalism. A list that included university
courses, undergraduate degree, graduate degree or course of study, workshops and
conferences was provided for advisers to mark. Some elected to mark "other" and
described that training.
For hypothesis two, advisers were asked closed-ended questions that offered a
statement with a Likert scale of possible answers. The first statement stated,
"The previous experiences of my administrator regarding student publications
have been positive." Advisers were asked to respond using a Likert scale of
1=strongly agree to 5=strongly disagree. Advisers also were asked to complete
the statement, "My administrator views prior review (reviewing a publication
prior to publication) as:" using a Likert scale of 1=highly favorable to
For research question one, advisers were asked in an open-ended question for
the average number of times per year the adviser had exercised prior restraint
by removing items before publication. Several responded with qualified word
responses such as "always," "rarely," "numerous," and "several," rather than
quantified responses. In order to statistically analyze responses, only
quantified numerical answers were considered. Other questions that addressed
research question one were similarly constructed and analyzed; these asked for
the average number of times per year advisers had exercised prior review, the
average number of times per year administrators had exercised prior review, and
the average number of times per year administrators had exercised prior
For research question two, demographic data (MHSAA classification) was
associated with advisers' responses to two questions. The first question asked
advisers to indicate the frequency with which they exercised prior review and/or
restraint using a Likert scale of 1=frequently to 5=never. The second question
(also used in hypothesis two) asked advisers to complete the statement, "My
administrator views prior review (reviewing a publication prior to publication)
as:" using a Likert scale of 1=highly favorable to 5=highly unfavorable.
For research question three, demographic data (MHSAA classification) was
associated with advisers' affirmative or negative responses to one question,
"Does your publication have a stated editorial policy?"
A randomly selected sample of 350 public, private and/or parochial secondary
schools in the state of Michigan was selected from the 720 high schools (public,
private and parochial) in the state that are associated with the Michigan High
School Athletic Association. Because two of the listed schools were not
classified as A, B, C, or D, only the 718 classified schools were considered for
the sample. A random numbers table was used to generate a list of 350 random
numbers from 1 to 718. Then the numbers were matched to their corresponding
school entry and a database for mailing purposes was created using FileMaker Pro
Included with the questionnaire was a cover letter that identified the source
of partial funding (Michigan Interscholastic Press Association) and the
rationale behind the research topic. Advisers were told in the cover letter that
their responses would be confidential, not anonymous, for mailing purposes. An
offer of sharing the results with advisers may have increased their willingness
to participate, as 52 of the 195 respondents (26.7 percent) requested a copy of
the results of the study.
Three waves of questionnaires were sent in order to maximize the response rate.
The first wave was sent to publication advisers at the 350 randomly-selected
secondary schools. Each letter and envelope was addressed to Student
Publications Adviser. This first wave consisted of the cover letter,
questionnaire and a stamped return envelope; 109 of 350 questionnaires were
returned. The second wave consisted of a postcard reminder about the survey to
all 350 potential respondents. It was sent three weeks after the initial mailing
and resulted in an additional 37 responses.
Though responses were kept confidential, the researcher used a numbering system
to determine which schools had returned questionnaires and which had not for
third-wave mailings. The third wave involved remailing the cover letter,
questionnaire and stamped return envelopes to all 208 non-respondents and
resulted in another 50 respondents returning questionnaires.
Demographics of respondents
The final response rate of 55% (195 of 354) was considered acceptable for a
mail-distributed questionnaire. Because not all respondents answered every
question, the respondent base number (n) is reported for each item.
Questionnaires were returned by 195 respondents respresenting 50 class A
schools (26%), 46 class B schools (24%), 51 class C schools (26%), and 48 class
D schools (24%) (SEprop =3.6). The MHSAA directory listed a population of high
schools that included 178 class A schools (25% of the total), 177 class B
schools (24%), 179 class C schools (25%), and 184 class D schools (26%); this
sample rather accurately reflected the true population. Of 194 respondents, 85%
worked at public schools, 7 % at parochial schools, 6% at private schools and 2%
at private parochial schools (SEprop =3.6).
Advisers were asked to mark as many of the given sources of continuing
education and training in journalism of which they had made use; some marked
multiple sources. Of 175 respondents, 61% said they had attended workshops and
33% had attended conferences. Twenty-seven percent said they had training
during an undergraduate degree program; 9% indicated they had received an
advanced degree or course of study; and 25% said they had taken university or
college courses in journalism (SEprop=3.8). Other listed sources of continuing
training were "on the job" experience (four responses), professional experience
as a reporter (three responses), and none (ten responses). (See Figure 1.)
Most of the conferences and workshops attended by respondents were offered by
Michigan State University and/or the Michigan Interscholastic Press Association
(38 mentions of workshops and 27 mentions of conferences) and the printing
companies (37 mentions of workshops and 7 mentions of conferences).
Advisers were asked to mark on a given list all the sources they used to gain
information about court decisions affecting student publications. Of 183
respondents, 62% received information from commercial newspapers, 50% from MIPA
publications, 25% from scholarly journals, 22% from news magazines, 22% from
principals, 7% from the Internet, 16% from conferences and 9% from workshops.
(See Figure 2.)
Relationship between advisers' experience and acts of censorship
Hypothesis one stated, "More experienced advisers will exercise prior review
and/or prior restraint less frequently." This hypothesis was not supported by
the research findings.
Previous research has indicated that advisers with more training were more
likely to address controversial topics.37 Advisers with less experience were
found to be most likely to seek assistance from an administrator regarding
content decisions and to make changes to controversial content.38 One study
found that advisers with less experience and training were more likely to
exercise censorship, 39 while other research has indicated that advisers with
more training are sometimes more likely to exercise censorship.40
Pearson correlations between the number of years advising and the average
number of times per year an adviser exercised the right of prior restraint were
not significant in a one-tailed test of significance with a Pearson correlation
coefficient of .02 at p=.399 (n=174). Years teaching were not associated with
incidence of adviser prior restraint to any degree of statistical significance
in a one-tailed test of significance either with a Pearson correlation
coefficient of -.05 at p=.254 (n=170).
An adviser's training and/or continuing education in journalism was associated
positively and to a significant degree only with acts of prior restraint in
terms of the variable "adviser has taken university or college courses in
journalism" (X2=38.95, d.f.=16, r=.049, p=.001). No other types of continuing
education or training in journalism were associated with adviser's acts of prior
restraint or adviser's acts of prior review to any statistically significant
Overall, an adviser's source of information about court decisions affecting
student publications was not associated to a statistically significant degree
with incidence of prior review or restraint. Incidence of adviser prior
restraint was associated with getting information from a principal (X2=31.36,
d.f.=21, p=.068) and with getting information from MIPA (X2=30.78, d.f.=21,
p=.077), and both associations tended toward significance.
Administrative influence on adviser censorship
Hypothesis two stated, "An adviser who perceives administration as more
favorable toward censorship will be more likely to exercise prior restraint."
This hypothesis was partially supported.
Previous research has indicated that nearly all high school principals said
they would censor certain subjects under specific circumstances, including
vulgar language, sex, drugs, and student pregnancy,41 and that inexperienced
advisers are more likely to change student copy when it is sensitive,
controversial, or critical of school administration.42
Advisers responded to a statement that their administrators' experiences
regarding student publications were positive using a Likert scale of 1=strongly
agree to 5=strongly disagree. Of 181 respondents, 79% agreed or strongly agreed
that their administrators' experiences had been positive. Thirty-three percent
"strongly agreed" their administrators' experiences had been positive, and 46%
"agreed;" 13% said they were "undecided." Only 7% said they "disagreed" that
their administrators' experiences had been positive, while 2% "strongly
disagreed." (See Figure 3.)
Advisers completed a statement of how favorably their administrators viewed
prior review using a Likert scale of 1=highly favorable to 5=highly unfavorable.
Of 170 respondents (SEprop=3.8), nearly 50% said they perceived their
administrators' views as favorable toward prior review, and only 14% said their
administrators did not view prior review as favorable. Thirty-eight percent said
their administrators viewed prior review as "highly favorable;" 11% said their
administrators viewed it as "slightly favorable;" 38% marked "neutral;" 6% said
their administrators viewed prior review as "slightly unfavorable;" and 8% said
their administrators viewed prior review as "highly unfavorable."
An adviser's perception of an administrator's previous experiences with student
publications was significantly correlated with the frequency with which an
adviser exercised the rights of prior review and/or restraint. Advisers who felt
their administrators' previous experiences with student publications had been
negative exercised prior review and restraint more frequently. The Pearson
correlation coefficient for both a two-tailed and a one-tailed test of
significance was -.25 at p=.001 (n=167).
An adviser's perception of how favorably an administrator viewed prior review
was significantly correlated with the frequency with which an adviser exercised
prior review and/or restraint. The more favorably an adviser thought an
administrator viewed the act of prior review and/or restraint, the more likely
an adviser was to exercise prior review and/or restraint. The Pearson
correlation coefficient for a one-tailed test of significance was .32 at p<.001
Frequency of adviser censorship
Research question one asked, "How likely to censor student publications are
Michigan advisers and administrators?" Only 28.4% of 176 respondents indicated
they did not exercise prior restraint. Another 3.4% said they exercised prior
restraint less than once per year, but not zero times per year, making a total
of 32% that had exercised prior restraint an average of less than once per year.
This occurred when advisers indicated acts of prior restraint had happened an
average of once in three years, for example. Only 15.3% said they had exercised
prior restraint an average of once per year, while 8% said once or twice per
year (average 1.5 times). Over 12% (12.5%) said they had exercised prior
restraint an average of twice per year. Just over 5% (5.1%) indicated they had
exercised prior restraint two to three times per year (average 2.5 times).
Seventeen percent indicated they had exercised prior restraint an average of
three to five times per year, while 8% said they had exercised prior six to nine
times per year. A rather small percentage, 2.4%, said they had exercised prior
restraint more than 10 times per year. (See Figure 4.)
When asked for the average number of times per year an adviser had delayed
publication through prior review, 83% of 175 respondents said they had delayed
publication through prior review an average of less than once per year. Only 5%
said they had delayed publication through prior review an average of once per
year, and 4% said they had delayed publication through prior review twice per
year. Just over 5% indicated they had delayed publication through prior review
more than twice per year. (See Figure 4.)
Advisers were asked for the average number of times per year their current
administrators had exercised prior restraint. Sixty-six percent of 182
respondents said their administrators had exercised prior restraint an average
of less than one time per year. Nineteen percent said once per year and 4% said
twice. Six percent said three to five times per year, and 2% said six to nine
times. Only 1% said their administrators had exercised prior restraint an
average of ten or more times per year. (See Figure 4.)
Advisers were asked in an open-ended question for the average number of times
per year their current administrator had delayed publication through prior
review. Eighty-seven percent of 177 respondents indicated their administrators
had delayed publication through prior review an average of less than one time
per year. Six percent said once per year and 2% said twice. Two percent said
their administrators had delayed publication through prior review an average of
three to five times per year and 1% said six to nine times per year. (See Figure
Advisers rated the frequency with which their administrators exercised the
right of prior review and/or restraint using a Likert scale of 1=frequently to
5=never. Advisers were also offered the option of marking "other" and describing
the frequency. Nine percent said their administrators exercised the right
"frequently;" 5% said "often;" 15% said "occasionally;" 30% said "rarely;" and
40% said "never." Only 1% marked "other." (See Figure 5.)
Advisers also rated how frequently they exercised the right of prior review
and/or restraint. Thirty-five percent said "frequently;" 12% said "often;" 24%
said "occasionally;" 21% said "rarely;" and 5% said "never." Three percent
marked "other." (See Figure 5.)
Relationship between school size and censorship
Research question two asked, "Does size of school affect the amount of
censorship, and if it does, what is the relationship and what are the given
reasons?" Previous research has indicated that school size affects the
frequency of censorship. One researcher said that administrators in smaller
schools tended to be less tolerant of student expression than administrators in
larger schools.43 Another study found that advisers in small, rural areas were
more likely to seek assistance from their administrators when making content
T-test comparisons of adviser's exercise of prior review and/or restraint among
the various classifications of schools tended toward significance between class
A and class C schools. Comparisons of class A and class C schools gave a
t-value of 1.89, d.f.=73.73, p=.063. (See Table 1.)
How favorably an adviser thought an administrator viewed prior review and MHSAA
classification of school were associated negatively (Pearson's R = -.304,
p<.001). Advisers from larger schools (class A) reported that administrators
were less likely to view prior review as favorable, while advisers from smaller
schools reported that administrators were more likely to favor prior review.
T-test comparisons of class A and class B schools gave a t-value of 3.14,
d.f.=74.69, p=.002. Comparisons of class A and class C schools gave a t-value
of 4.23, d.f.=66.03, p<.001. Comparisons of class A and class D schools gave a
t-value of 3.30, d.f.=67.71, p=.002. (See Table 2.)
Relationship between school size and editorial policy
Research question three asked, "Does size of school affect whether that school
has an editorial policy regarding student publications?" Previous research has
found that not having written policies on appropriate content affected the rate
of censorship.45 Another study found that only 48 percent of Florida high
schools surveyed had a written editorial policy.46
In this study, respondents were asked if their publication had a stated
editorial policy. Seventy percent of 185 respondents indicated their
publication did not have a stated editorial policy (SEprop=3.7). Of these 185
respondents, 49 were from class A schools, 44 from class B, 50 from class C and
42 from class D. Larger schools were significantly more likely to have stated
editorial policies than smaller schools. Forty-nine percent of class A schools
had stated policies, while only 39% of class B schools, 22% of class C schools
and 10% of class D schools did (X2=19.77, d.f.=3, p<.001).
Limits on freedom of speech and press for high school students may threaten the
freedoms of us all. In Michigan, a majority of administrators and nearly half of
advisers are not restricting students' press rights on a frequent basis, yet
there appears to be the potential for increased censorship in schools of all
The majority of Michigan's student publications advisers agreed or strongly
agreed their administrators' previous experiences with student publications had
been positive, yet nearly half said they perceived that their administrators
viewed prior review as highly or slightly favorable. Advisers who felt their
administrators' previous experiences with student publications had been negative
exercised the rights of prior review and/or restraint more frequently. The more
favorably an adviser thought an administrator viewed the act of prior review
and/or restraint, the more likely an adviser was to exercise prior review and/or
The majority of Michigan advisers said their administrators exercise prior
restraint or prior review one or fewer times per year and nearly half (47%) of
advisers exercise prior restraint one or fewer times per year. Only 18% of
advisers said they delay publication through prior review in an average year,
yet 35% said they exercised the right of prior review and/or restraint
frequently. Twelve percent said they exercised the right often and 24% said
occasionally. Only 21% said rarely and a meager 5% said never. This means that
95% of advisers said they are exercising prior review and/or restraint over
School size affected not only how favorably advisers thought administrators
viewed prior review, but also whether a student publication was likely to have a
stated editorial policy. How favorably advisers in larger schools (class A)
thought administrators viewed prior review differed significantly from how
favorably advisers in smaller schools (classes B, C, and D) thought
administrators viewed prior review. Only 30% of advisers indicated their school
had a stated editorial policy for student publications.
Is removing items from student publications good teaching practice? Is removing
items prior to publication a method of teaching, or does it just solve the
immediate problem of inappropriate or inaccurate material existing in a
publication? How do editorial policies enhance or hinder attempts to restrict
content in student publications?
This study found that of 185 respondents, 30% said their school did have a
stated editorial policy, while 70% said their school did not have such a policy.
Additionally, larger schools were more likely to have stated policies than
smaller schools. While the Dodd and Mays study on Florida high school editorial
policies, which found that 48% of schools surveyed had an editorial policy, was
done over four years ago, perhaps Michigan high schools have not had an impetus
to draft and enact policies on student publications. In fact, one respondent
indicated that s/he would like to have a policy but needed a model. Although
correlations were not statistically significant with these research findings,
future research might address the correlation between existence of a written
editorial policy and incidence of censorship by administrators and advisers.
Without surveying administrators about their attitudes toward prior review
and/or restraint and their past experiences with student publications, one
cannot be sure of the accuracy of advisers' perceptions of these attitudes and
experiences. Conceivably, a pattern of miscommunication could have led to
advisers believing one thing while administrators believe another. Instituting
editorial policies could open the lines of communication between advisers and
their administrators and decrease misperceptions, if they exist. In turn, this
could lead to fewer incidences of prior review and/or restraint, as advisers may
not fear adminstrative censure or employment repercussions.
Drafting editorial policies might help advisers, principals and students come
to agreement on when and how student publications should address sensitive or
mature topics. Additionally, working together on an editorial board to enforce
editorial policies would cultivate a continued sense of community and shared
responsibility within the school. Perhaps this sense of cooperation would help
diminish adversarial relationships among students and advisers and principals.
Although this research did not produce statistically significant correlations,
future research might look at the relationship between membership in state and
national associations and incidence of censorship by administrators and
The seeming contradictions in these findings suggest that additional studies
along the lines of those done by Click and Kopenhaver and Dickson need to be
done to determine how Michigan's advisers define censorship, including prior
review and prior restraint. Additionally, state and national press associations
must continue to address these topics in light of legal developments through
conferences and workshops. Universities offering undergraduate preparation for
advising scholastic publications should also offer coursework which addresses
these topics and appropriate teaching methods.
So, what does this study mean for state and national press associations?
Because the bulk of advisers indicate that they are getting their information
and training from conferences and workshops, it is imperative that press
associations continue to offer workshops and conference sessions that relate to
scholastic press laws. Additionally, based on the findings that fewer than half
of Florida high schools and only 30% of Michigan high schools have written
editorial policies, perhaps state and national press associations should
consider offering workshops and/or conference sessions that address the
importance of having written editorial policies as well as how to draft them.
Figure 1: Sources of respondents' continuing education and training in
*Percentages total more than 100% because respondents were asked to mark all
sources that applied to them.
Figure 2: Sources of respondents' information about court decisions affecting
student publications (n=183)
*Percentages total more than 100% because respondents were asked to mark all
sources that applied to them.
Figure 3: Adviser perceives that administrator's previous experiences with
student publications have been positive (n=181)
Figure 4: Average incidences of censorship in an average year
Figure 5: Adviser's report of exercise of prior restraint (n=183)
Table 1: T-test comparisons of advisers' self-reports of exercise of prior
review/restraint by MHSAA classification (two-tailed tests of significance)
degrees of freedom (d.f.)
(A=40, B=37, C=42, D=37; A-mean=2.83, B-mean=2.49, C-mean=2.26, D-mean=2.49)
Table 2: T-test comparisons of advisers' reports of administrators' view of
prior review and MHSAA classification (two-tailed test of significance)
degrees of freedom (d.f.)
(A=40, B=37, C=42, D=37; A-mean=3.05, B-mean=2.08, C-mean=1.90, D-mean=2.14)
Table 3: Chi-square table of existence of stated editorial policy by MHSAA
Total for all schools
did not have
1 Tinker v. Des Moines Independent Community School District 393 U.S. 503
2 Ibid., 506.
3 Bethel School District No. 403 v. Fraser 478 U.S. 675 (1986).
4 Board of Education, Island Trees Union Free School District No. 26 v. Pico
457 U.S. 853 (1982).
5 Ibid., 871.
7 478 U.S. 675, 685.
8 Hazelwood School District b. Kuhlmeier 108 S.Ct. 562 (1988).
9 Ibid., 563, 570.
10 Hafen, Bruce C., "Hazelwood School District and the Role of First Amendment
Institutions," Duke Law Journal, 1988, 690, 691 (citing 478 U.S. 675, 685).
11 Hafen, 693.
12 Ibid., 694.
13 108 S.Ct. 562.
14 Ibid., 694.
15 Ibid., 685.
16 108 S.Ct. 562, 573.
17 Abrams, J. Marc, and S. Mark Goodman, "End of an Era? : The Decline of
Student Press Rights in the Wake of Hazelwood School District v. Kuhlmeier,"
Duke Law Journal, 1988, 722-723,727; and Sherry, Susanna, "Responsible
Republicanism: Educating for Citizenship," The University of Chicago Law
Review, 1995, 191.
18 Dvorak, Jack and Jon Paul Dilts, "Academic Freedom vs. Administrative
Authority," Journalism Educator, Autumn 1992, 7.
19 Eveslage, Thomas, "Advisers Know About Student Rights, But . . ." Quill and
Scroll, December-January 1981, 12.
20 Ibid., 13.
22 Dodd, Julie E., "Principals', Advisers' Evaluations of the Important
Characteristics for Newspaper Advisers," Quill and Scroll, April-May 1983, 15.
23 Arnold, Mary, "Student Freedom of Expression and High School Journalism
Advisers: A legal and educational dilemma," Quill and Scroll, December-January
24 Dickson, Thomas V., "What's a Good Adviser to Do?" C:JET, Spring, 1995, 12.
26 Dickson, Thomas V., "Attitudes of High School Principals About Press Freedom
After Hazelwood," Journalism Quarterly, Spring 1989, 171.
27 Salomone, Rosemary C., "The Impact of Hazelwood v. Kuhlmeier on Local Policy
and Practice," NASSP Bulletin, December 1994, 53, 58-59.
28 Dickson, 1989, 173.
29 Ibid., 172.
30 Dickson, Thomas V., "Self-Censorship and Freedom of the High School Press,"
Journalism Educator, Autumn 1994, 63.
31 Dvorak, Jack, Lawrence Lain and Tom Dickson, Journalism Kids Do Better: What
research tells us about high school journalism in the 1990s, ERIC, 1994,
32 Dvorak, Lain and Dickson, 264.
33 Eveslage, 12.
34 Ibid., 13.
35 Dodd, Julie E. and Roy P. Mays, "The impact of Hazelwood v. Kuhlmeier on
publication policies in Florida high schools," Quill and Scroll,
October-November 1993, 13.
36 The Freedom Forum, "You can't print that! Student press rights and
responsibilities," Death by Cheeseburger, The Freedom Forum, 1994.
37 Dodd, 15.
38 Arnold, 9.
39 Eveslage, 12.
40 Dickson, 1994, 63.
41 Dickson, 1989, 171.
42 Arnold, 9.
43 Dickson, 1989, 173.
44 Arnold, 9.
45 Eveslage, 12.
46 Dodd and Mays, 13.
 In 1996-97, the Michigan High School Athletic Association classified
schools with 985 or more students as A, 519-984 as B, 262-518 as C, and less
than 261 as D.