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 control over student speech in school-sponsored expressive activities. But given that Hazelwood serves as the “polestar” that guides the Eleventh Circuit’s test in Bishop (discussed at length infra) this Court takes a brief detour to examine Hazelwood’s contours.

Hazelwood involved a school principal’s decision to censor high school students’ articles in a school-sponsored newspaper. The Supreme Court held that the newspaper, along with “other expressive activities that students, parents, and members of the public might reasonably perceive to bear the imprimatur of the school,” may be “fairly characterized as part of the school curriculum … so long as they are supervised by faculty members and designed to impart particular knowledge or skills to student participants and audiences.” Hazelwood, 484 U.S. at 271. As such, the Supreme Court further held that “educators do not offend the First Amendment by exercising editorial control over the style and content of student speech in school-sponsored expressive activities so long as their actions are reasonably related to legitimate pedagogical concerns.” Id. at 273. But in so holding, the Court declined to determine whether this same standard applies to school-sponsored expressive activities at the university level. Id. n.7. Regardless, the Eleventh Circuit reads Hazelwood to offer “no indication that the [Supreme] Court intended to drastically rewrite First Amendment law to allow a school official to discriminate based on a speaker’s views.” Searcey v. Harris, 888 F.2d 1314, 1319