On January 17, 2012, the U.S. Supreme Court denied the request of two school boards to review the decisions of the U.S. Third Circuit Court of Appeals in J.S. v. Blue Mountain School District and Layshock v. Hermitage School District.  In those cases, the court of appeals determined that the school boards lacked authority to discipline students who, using their home computers, created fake web sites mocking their respective principals.  The court of appeals concluded that the First Amendment’s guarantee of freedom of speech insulated the students from discipline for off-campus speech because the speech did not cause a substantial disruption of the school environment and could not be viewed as reasonably likely to do so. 

The school boards asked the Supreme Court to review the cases so that the Supreme Court could publish a rule outlining the scope of authority of school officials to discipline students for such off-campus speech.  Although neither case involved internet speech targeting students, the school boards had hoped the Supreme Court would address that issue as well.