Supreme Court Quartet: Summary of Holdings

1) Tinker - applies to student speech in the form of personal political expression. If Tinker applies, to justify discipline of students for their expression, the school must show either 1) the student speech caused actual substantial disruption of school activities or 2) the school could reasonably forecast that the speech would cause substantial disruption.

2) Fraser - school may discipline students for lewd, vulgar, indecent or profane speech (without showing the speech had any particular impact; in other words without satisfying Tinker). Under Fraser, the school is disciplining students for their manner of expression (their particular word choices) and not based on the underlying message they sought to communicate. In Morse, the Supreme Court made clear that speech does not fall within the Fraser category because it is offensive, but only if it is lewd, vulgar, indecent, or profane.

3) Kuhlmeier - school may censor speech that occurs as part of a school-sponsored expressive activity (speech that will be perceived as bearing the imprimatur of the school) if its action is reasonably related to a legitimate educational objective. 

4) Morse - school may discipline students for speech that occurs during school or during a school event (even if the event takes place off campus) if the speech promotes illegal drug use when the school has a strong antidrug policy (without showing the speech had any particular impact; in other words without satisfying Tinker). Morse involved speech at a school event, but not school-sponsored expression that would be governed by Kuhlmeier.