Teacher Resources: Lesson Plan

Students and the Supreme Court

Overview

Students often assume that, as minors, they have the same protection under the law as adults, but this is not correct. The Supreme Court only began to render interpretations about the legal rights of young people in 1899 when juvenile courts were established. The extension of the 14th Amendment due process clause to students in school was finally accomplished in the case of Goss v. Lopez (1975). Students will learn about the background incident and 10-day suspension which sparked Goss v. Lopez, read the opinion for the majority and the dissent in this 5-4 decision, listen to audio files of oral arguments before the Supreme Court during the case, and write an evaluation of whether this ruling is likely to stand. This lesson is designed for high school students in either Government/Civics or U.S. History, grades 9-12.

National Curriculum Standards met by this lesson

For a list of standards that this unit addresses, click here.

Ties to your Curriculum

This lesson may be used when you review your district's student rights and responsibilities statement at the outset of the school year.

This lesson ties into United States Government/Civics when studying:

This lesson ties into United States History when studying:

Time required

The lesson will take two class periods if written work is done outside of class.

Materials

(Both opinions in their entirety may be located at http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=US&navby=case&vol=419&invol=565&friend=oyez

The Lesson

In advance of this lesson ask students to go through the Constitution of the United States to find out if it says anything about the legal rights of juveniles or students. (It doesn't.) Suggest to students that they speak with their parents or older members of the community about school rules and punishments of the past, from dress codes to corporal punishment as they prepare for this activity.

Anticipatory Set


  1. Explain to students the reasons why the Constitution and Bill of Rights were silent on their rights by pointing out that, at the time the Constitution was written, infants (by tradition those below the age of 7) were presumed to be incapable of criminal intent, but children ages 7 and above were arrested, tried, and punished as adults. Although the 9th Amendment guarantees that rights not enumerated in the Constitution are retained by the people, it took more than a hundred years before the federal government began to identify and define the rights of juveniles. During the 19th century era of reform the Society for the Prevention of Juvenile Delinquency urged for a separation of juvenile and adult offenders and for the establishment of a separate juvenile court system. The first juvenile court was established in Cook County, Illinois in 1899. By 1925, all but two states had juvenile courts; since 1945, all states have had separate juvenile systems. Because there was a gap in procedure between adult and juvenile courts, the Supreme Court responded with rulings in Kent v. United States (1966) and In re Gault (1967) by applying the 14th Amendment's due process clause to juveniles.
  2. The previous cases have to do with legal rights in criminal cases, but not about students' rights in schools. Explain that in December, 1965, 15-year old John Tinker and his three siblings, ranging from 8 to 13 years of age were suspended indefinitely from their schools in Des Moines, Iowa for wearing black armbands in protest of the Vietnam War. Although the students removed their armbands after New Year's Day, 1966, the case went to the Supreme Court as Tinker v. Des Moines (1969). In a 7-2 decision the court ruled that students' right to education could not be denied, nor their First Amendment rights to freedom of speech (in this case, symbolic speech.)
  3. Show students a photocopy of the letter (below) from the Alamo Heights Student Council to Supreme Court Associate Justice William O. Douglas. Ask students what student rights are guaranteed by their school district and whether it is just because the school board is being nice to them or whether it is a recognized right under law.
  4. Explain that they will be studying Goss v. Lopez because it is the case which extended the 14th Amendment's due process clause to students in school. State legislatures or school districts may grant more rights to students, but at the minimum must provide students with a hearing before suspending them for more than 10 days. Because Ralph Evans' letter was received by the Clerk of the Supreme Court before the decision had been made, the clerk replied by advising him to write to the attorneys in the case.

Courtesy of the National Archives and Records Administration, Washington, DC. Records of the United States Supreme Court, RG 267, Ralph Evans' letter to Justice William O. Douglas about Goss v. Lopez, 1974

Procedures

  1. Set the background of the case by explaining that there had been race related student disturbances at Central High School in Columbus, Ohio. After a February 1971 riot in the lunchroom and damage to school property, the principal suspended 75 pupils. Among them was Dwight Lopez, suspended for 10 days, but who insisted he was an innocent bystander. Unable to get a hearing to review the suspension, Lopez and 8 other students sought redress through the courts. The case was appealed to the Supreme Court where oral arguments were made and a decision reached in the case of Goss v. Lopez (1975).
  2. Ask for volunteers to read a paragraph at a time from the extracts of Justice Byron R. White's opinion for the majority and Justice Lewis F. Powell's dissent. At the end of each paragraph of White's opinion, ask members of the class to summarize aloud the main information, issue, and/or argument presented in the paragraph and write it down on a notebook sheet titled "Opinion for the Majority." At the end of each paragraph of Powell's opinion, ask members of the class to summarize aloud the main information, issue, and/or argument presented in the paragraph and write it down on a notebook sheet titled "Dissenting Opinion." After finishing the two opinions, discuss whether White's hope for fair application of justice in schools and Powell's concerns about the intrusion of the courts in the schools have come true.

    3. MR. JUSTICE WHITE delivered the opinion of the Court.

    This appeal by various administrators of the Columbus, Ohio, Public School System (CPSS) challenges the judgment of a three-judge federal court, declaring that appellees--various high school students in the CPSS--were denied due process of law contrary to the command of the Fourteenth Amendment in that they were temporarily suspended from their high schools without a hearing either prior to suspension or within a reasonable time thereafter, and enjoining the administrators to remove all references to such suspensions from the students' records.

    I

    Ohio law, Rev. Code Ann. § 3313.64 (1972), provides for free education to all children between the ages of six and 21. Section 3313.66 of the Code empowers the principal of an Ohio public school to suspend a pupil for misconduct for up to 10 days or to expel him. In either case, he must notify the student's parents within 24 hours and state the reasons for his action. A pupil who is expelled, or his parents, may appeal the decision to the Board of Education and in connection therewith shall be permitted to be heard at the board meeting. The Board may reinstate the pupil following the hearing. No similar procedure is provided in § 3313.66 or any other provision of state law for a suspended student.

    The nine named appellees, each of whom alleged that he or she had been suspended from public high school in Columbus for up to 10 days without a hearing pursuant to § 3313.66, filed an action under 42 U. S. C. § 1983 against the Columbus Board of Education and various administrators of the CPSS. The complaint sought a declaration that § 3313.66 was unconstitutional in that it permitted public school administrators to deprive plaintiffs of their rights to an education without a hearing of any kind, in violation of the procedural due process component of the Fourteenth Amendment.

    The proof below established that the suspensions arose out of a period of widespread student unrest in the CPSS during February and March 1971...Two named plaintiffs, Dwight Lopez and Betty Crome, were students at the Central High School and McGuffey Junior High School, respectively. The former was suspended in connection with a disturbance in the lunchroom which involved some physical damage to school property. Lopez testified that at least 75 other students were suspended from his school on the same day. He also testified below that he was not a party to the destructive conduct but was instead an innocent bystander. Because no one from the school testified with regard to this incident, there is no evidence in the record indicating the official basis for concluding otherwise. Lopez never had a hearing.

    On the basis of this evidence, the three-judge court declared that plaintiffs were denied due process of law because they were "suspended without hearing prior to suspension or within a reasonable time thereafter," and that Ohio Rev. Code Ann. § 3313.66 (1972) and regulations issued pursuant thereto were unconstitutional in permitting such suspensions.

    The defendant school administrators have appealed the three-judge court's decision.

    II

    At the outset, appellants contend that because there is no constitutional right to an education at public expense, the Due Process Clause does not protect against expulsions from the public school system. This position misconceives the nature of the issue and is refuted by prior decisions. The Fourteenth Amendment forbids the State to deprive any person of life, liberty, or property without due process of law. Protected interests in property are normally "not created by the Constitution. Rather, they are created and their dimensions are defined" by an independent source such as state statutes or rules entitling the citizen to certain benefits. Board of Regents v. Roth, 408 U.S. 564, 577 (1972)...

    Here, on the basis of state law, appellees plainly had legitimate claims of entitlement to a public education. Ohio Rev. Code Ann. §§ 3313.48 and 3313.64 (1972 and Supp. 1973) direct local authorities to provide a free education to all residents between five and 21 years of age, and a compulsory-attendance law requires attendance for a school year of not less than 32 weeks...

    Although Ohio may not be constitutionally obligated to establish and maintain a public school system, it has nevertheless done so and has required its children to attend. Those young people do not "shed their constitutional rights" at the schoolhouse door. Tinker v. Des Moines School Dist., 393 U.S. 503, 506 (1969). "The Fourteenth Amendment, as now applied to the States, protects the citizen against the State itself and all of its creatures--Boards of Education not excepted." West Virginia Board of Education v. Barnette, 319 U.S. 624, 637 (1943). The authority possessed by the State to prescribe and enforce standards of conduct in its schools although concededly very broad, must be exercised consistently with constitutional safeguards. Among other things, the State is constrained to recognize a student's legitimate entitlement to a public education as a property interest which is protected by the Due Process Clause and which may not be taken away for misconduct without adherence to the minimum procedures required by that Clause.

    The Due Process Clause also forbids arbitrary deprivations of liberty. "Where a person's good name, reputation, honor, or integrity is at stake because of what the government is doing to him," the minimal requirements of the Clause must be satisfied. Wisconsin v. Constantineau, 400 U.S. 433, 437 (1971); Board of Regents v. Roth, supra, at 573. School authorities here suspended appellees from school for periods of up to 10 days based on charges of misconduct. If sustained and recorded, those charges could seriously damage the students' standing with their fellow pupils and their teachers as well as interfere with later opportunities for higher education and employment. It is apparent that the claimed right of the State to determine unilaterally and without process whether that misconduct has occurred immediately collides with the requirements of the Constitution.

    Appellants proceed to argue that even if there is a right to a public education protected by the Due Process Clause generally, the Clause comes into play only when the State subjects a student to a "severe detriment or grievous loss." The loss of 10 days, it is said, is neither severe nor grievous and the Due Process Clause is therefore of no relevance. Appellants' argument is again refuted by our prior decisions... A 10-day suspension from school is not de minimis in our view and may not be imposed in complete disregard of the Due Process Clause.

    A short suspension is, of course, a far milder deprivation than expulsion. But, "education is perhaps the most important function of state and local governments," Brown v. Board of Education, 347 U.S. 483, 493 (1954), and the total exclusion from the educational process for more than a trivial period, and certainly if the suspension is for 10 days, is a serious event in the life of the suspended child.

    III

    "Once it is determined that due process applies, the question remains what process is due." Morrissey v. Brewer, 408 U.S., at 481. ...At the very minimum, therefore, students facing suspension and the consequent interference with a protected property interest must be given some kind of notice and afforded some kind of hearing...

    The student's interest is to avoid unfair or mistaken exclusion from the educational process, with all of its unfortunate consequences. The Due Process Clause will not shield him from suspensions properly imposed, but it disserves both his interest and the interest of the State if his suspension is in fact unwarranted. The concern would be mostly academic if the disciplinary process were a totally accurate, unerring process, never mistaken and never unfair. Unfortunately, that is not the case, and no one suggests that it is.

    The difficulty is that our schools are vast and complex. Some modicum of discipline and order is essential if the educational function is to be performed. Events calling for discipline are frequent occurrences and sometimes require immediate, effective action. Suspension is considered not only to be a necessary tool to maintain order but a valuable educational device. The prospect of imposing elaborate hearing requirements in every suspension case is viewed with great concern, and many school authorities may well prefer the untrammeled power to act unilaterally, unhampered by rules about notice and hearing. But it would be a strange disciplinary system in an educational institution if no communication was sought by the disciplinarian with the student in an effort to inform him of his dereliction and to let him tell his side of the story in order to make sure that an injustice is not done.

    We do not believe that school authorities must be totally free from notice and hearing requirements if their schools are to operate with acceptable efficiency. Students facing temporary suspension have interests qualifying for protection of the Due Process Clause, and due process requires, in connection with a suspension of 10 days or less, that the student be given oral or written notice of the charges against him and, if he denies them, an explanation of the evidence the authorities have and an opportunity to present his side of the story. The Clause requires at least these rudimentary precautions against unfair or mistaken findings of misconduct and arbitrary exclusion from school.

    We agree with the District Court, however, that there are recurring situations in which prior notice and hearing cannot be insisted upon. Students whose presence poses a continuing danger to persons or property or an ongoing threat of disrupting the academic process may be immediately removed from school. In such cases, the necessary notice and rudimentary hearing should follow as soon as practicable, as the District Court indicated.

    We stop short of construing the Due Process Clause to require, countrywide, that hearings in connection with short suspensions must afford the student the opportunity to secure counsel, to confront and cross-examine witnesses supporting the charge, or to call his own witnesses to verify his version of the incident. Brief disciplinary suspensions are almost countless. To impose in each such case even truncated trial-type procedures might well overwhelm administrative facilities in many places and, by diverting resources, cost more than it would save in educational effectiveness. Moreover, further formalizing the suspension process and escalating its formality and adversary nature may not only make it too costly as a regular disciplinary tool but also destroy its effectiveness as part of the teaching process.

    We should also make it clear that we have addressed ourselves solely to the short suspension, not exceeding 10 days. Longer suspensions or expulsions for the remainder of the school term, or permanently, may require more formal procedures. Nor do we put aside the possibility that in unusual situations, although involving only a short suspension, something more than the rudimentary procedures will be required.

    IV

    The District Court found each of the suspensions involved here to have occurred without a hearing, either before or after the suspension, and that each suspension was therefore invalid and the statute unconstitutional insofar as it permits such suspensions without notice or hearing. Accordingly, the judgment is Affirmed.

    MR. JUSTICE POWELL, with whom THE CHIEF JUSTICE, MR. JUSTICE BLACKMUN, and MR. JUSTICE REHNQUIST join, dissenting.

    The Court today invalidates an Ohio statute that permits student suspensions from school without a hearing "for not more than ten days." The decision unnecessarily opens avenues for judicial intervention in the operation of our public schools that may affect adversely the quality of education. The Court holds for the first time that the federal courts, rather than educational officials and state legislatures, have the authority to determine the rules applicable to routine classroom discipline of children and teenagers in the public schools. It justifies this unprecedented intrusion into the process of elementary and secondary education by identifying a new constitutional right: the right of a student not to be suspended for as much as a single day without notice and a due process hearing either before or promptly following the suspension.

    The Court's decision rests on the premise that, under Ohio law, education is a property interest protected by the Fourteenth Amendment's Due Process Clause and therefore that any suspension requires notice and a hearing. In my view, a student's interest in education is not infringed by a suspension within the limited period prescribed by Ohio law. Moreover, to the extent that there may be some arguable infringement, it is too speculative, transitory, and insubstantial to justify imposition of a constitutional rule.

    I

    ...The Ohio statute that creates the right to a "free" education also explicitly authorizes a principal to suspend a student for as much as 10 days. Ohio Rev. Code Ann. §§ 3313.48, 3313.64, 3313.66 (1972 and Supp. 1973). Thus the very legislation which "defines" the "dimension" of the student's entitlement, while providing a right to education generally, does not establish this right free of discipline imposed in accord with Ohio law. Rather, the right is encompassed in the entire package of statutory provisions governing education in Ohio--of which the power to suspend is one...The Court thus disregards the basic structure of Ohio law in posturing this case as if Ohio had conferred an unqualified right to education, thereby compelling the school authorities to conform to due process procedures in imposing the most routine discipline.

    But however one may define the entitlement to education provided by Ohio law, I would conclude that a deprivation of not more than 10 days' suspension from school, imposed as a routine disciplinary measure, does not assume constitutional dimensions... The Ohio suspension statute allows no serious or significant infringement of education. It authorizes only a maximum suspension of eight school days, less than 5% of the normal 180-day school year. Absences of such limited duration will rarely affect a pupil's opportunity to learn or his scholastic performance. Indeed, the record in this case reflects no educational injury to appellees. Each completed the semester in which the suspension occurred and performed at least as well as he or she had in previous years.

    The Court also relies on a perceived deprivation of "liberty" resulting from any suspension, arguing--again without factual support in the record pertaining to these appellees--that a suspension harms a student's reputation.

    II

    In prior decisions, this Court has explicitly recognized that school authorities must have broad discretionary authority in the daily operation of public schools. This includes wide latitude with respect to maintaining discipline and good order. Addressing this point specifically, the Court stated in Tinker v. Des Moines School Dist., 393 U.S. 503, 507 (1969):

    "[The] Court has repeatedly emphasized the need for affirming the comprehensive authority of the States and of school officials, consistent with fundamental constitutional safeguards, to prescribe and control conduct in the schools."

    The Court today turns its back on these precedents. It can hardly seriously be claimed that a school principal's decision to suspend a pupil for a single day would "directly and sharply implicate basic constitutional values."

    ...Moreover, the Court ignores the experience of mankind, as well as the long history of our law, recognizing that there are differences which must be accommodated in determining the rights and duties of children as compared with those of adults. Examples of this distinction abound in our law: in contracts, in torts, in criminal law and procedure, in criminal sanctions and rehabilitation, and in the right to vote and to hold office. Until today, and except in the special context of the First Amendment issue in Tinker, the educational rights of children and teenagers in the elementary and secondary schools have not been analogized to the rights of adults or to those accorded college students. Even with respect to the First Amendment, the rights of children have not been regarded as "co-extensive with those of adults." Tinker, supra, at 515 (STEWART, J., concurring).

    A

    ...Unlike the divergent and even sharp conflict of interests usually present where due process rights are asserted, the interests here implicated--of the State through its schools and of the pupils--are essentially congruent.

    The State's interest, broadly put, is in the proper functioning of its public school system for the benefit of all pupils and the public generally. Few rulings would interfere more extensively in the daily functioning of schools than subjecting routine discipline to the formalities and judicial oversight of due process. Suspensions are one of the traditional means--ranging from keeping a student after class to permanent expulsion--used to maintain discipline in the schools. It is common knowledge that maintaining order and reasonable decorum in school buildings and classrooms is a major educational problem, and one which has increased significantly in magnitude in recent years. Often the teacher, in protecting the rights of other children to an education (if not his or their safety), is compelled to rely on the power to suspend. ..if hearings were required for a substantial percentage of short-term suspensions, school authorities would have time to do little else.

    B

    The State's generalized interest in maintaining an orderly school system is not incompatible with the individual interest of the student. Education in any meaningful sense includes the inculcation of an understanding in each pupil of the necessity of rules and obedience thereto. This understanding is no less important than learning to read and write. One who does not comprehend the meaning and necessity of discipline is handicapped not merely in his education but throughout his subsequent life. In an age when the home and church play a diminishing role in shaping the character and value judgments of the young, a heavier responsibility falls upon the schools...

    The lesson of discipline is not merely a matter of the student's self-interest in the shaping of his own character and personality; it provides an early understanding of the relevance to the social compact of respect for the rights of others. The classroom is the laboratory in which this lesson of life is best learned. Mr. Justice Black summed it up:

    "School discipline, like parental discipline, is an integral and important part of training our children to be good citizens--to be better citizens." Tinker, 393 U.S., at 524 (dissenting opinion).

    C

    One of the more disturbing aspects of today's decision is its indiscriminate reliance upon the judiciary, and the adversary process, as the means of resolving many of the most routine problems arising in the classroom. In mandating due process procedures the Court misapprehends the reality of the normal teacher-pupil relationship. There is an ongoing relationship, one in which the teacher must occupy many roles--educator, adviser, friend, and, at times, parent-substitute. It is rarely adversary in nature except with respect to the chronically disruptive or insubordinate pupil whom the teacher must be free to discipline without frustrating formalities.

    The Ohio statute, providing as it does for due notice both to parents and the Board, is compatible with the teacher-pupil relationship and the informal resolution of mistaken disciplinary action. We have relied for generations upon the experience, good faith and dedication of those who staff our public schools, and the nonadversary means of airing grievances that always have been available to pupils and their parents. One would have thought before today's opinion that this informal method of resolving differences was more compatible with the interests of all concerned than resort to any constitutionalized procedure, however blandly it may be defined by the Court.

    III

    No one can foresee the ultimate frontiers of the new "thicket" the Court now enters. Today's ruling appears to sweep within the protected interest in education a multitude of discretionary decisions in the educational process. Teachers and other school authorities are required to make many decisions that may have serious consequences for the pupil. They must decide, for example, how to grade the student's work, whether a student passes or fails a course, whether he is to be promoted, whether he is required to take certain subjects, whether he may be excluded from interscholastic athletics or other extracurricular activities, whether he may be removed from one school and sent to another, whether he may be bused long distances when available schools are nearby, and whether he should be placed in a "general," "vocational," or "college-preparatory" track.

    It hardly need be said that if a student, as a result of a day's suspension, suffers "a blow" to his "self esteem," "feels powerless," views "teachers with resentment," or feels "stigmatized by his teachers," identical psychological harms will flow from many other routine and necessary school decisions. The student who is given a failing grade, who is not promoted, who is excluded from certain extracurricular activities, who is assigned to a school reserved for children of less than average ability, or who is placed in the "vocational" rather than the "college preparatory" track, is unlikely to suffer any less psychological injury than if he were suspended for a day for a relatively minor infraction.

    If, as seems apparent, the Court will now require due process procedures whenever such routine school decisions are challenged, the impact upon public education will be serious indeed. The discretion and judgment of federal courts across the land often will be substituted for that of the 50 state legislatures, the 14,000 school boards, and the 2,000,000 teachers who heretofore have been responsible for the administration of the American public school system. If the Court perceives a rational and analytically sound distinction between the discretionary decision by school authorities to suspend a pupil for a brief period, and the types of discretionary school decisions described above, it would be prudent to articulate it in today's opinion. Otherwise, the federal courts should prepare themselves for a vast new role in society.

  3. Next, as they listen to the oral arguments, direct students to underline or mark on the extracted opinions where these arguments are repeated. Afterwards, discuss the role of lawyers who appear before the Supreme Court and why so little attention is paid to them, in contrast to most other cases which are reported in the media.
  4. The Supreme Court ruled 5-4 in Goss v. Lopez that students have a right to an education which may not be deprived without due process under the 14th Amendment. As a culminating activity, remind students that many split decisions have been reversed in the history of the Supreme Court. Direct students to refer to their notes and then write a paper in which they select and explain which argument of the majority opinion is most likely to survive and continue to preserve students' rights, and why.

Assessment

The students' papers may be evaluated on a twenty-point scale (which may be multiplied by five to convert to 100-point scale or for conversion to letter grades) using the following rubric:

 

Excellent

Good

Fair

Not Satisfactory

No Work

Historical Comprehension

10 points

(10) Written assignment demonstrates excellent

  • analysis of information about the court case
  • command of facts

formulation of opinion

(9-8) Written assignment demonstrates good

  • analysis of information about the court case
  • command of facts
  • formulation of opinion

(7-6) Written assignment shows fair or incomplete

  • analysis of information about the court case
  • command of facts
  • formulation of opinion

(5-1) Written assignment shows little or no

  • analysis of information
  • command of facts
  • formulation of opinion

0

Technical Writing Skills

10 points

(10) Written assignment shows excellent

  • compositional structure
  • sentence structure and variety
  • vocabulary use
  • grammar, spelling, punctuation

(9-8) Written assignment shows good

  • compositional structure
  • sentence structure and variety
  • vocabulary use
  • grammar, spelling, punctuation

(7-6) Written assignment shows adequate

  • compositional structure
  • sentence structure and variety
  • vocabulary use
  • grammar, spelling, punctuation

(5-1) Written assignment shows inadequate

  • compositional structure
  • sentence structure and variety
  • vocabulary use
  • grammar, spelling, punctuation

0

Related Works

ABA Division for Public Education: Teachers and Students, Online Conversations--Tinker v. Des Moines School Plaintiffs
http://www.abanet.org/publiced/lawday/tinker/home.html

Supreme Court Historical Society, The Learning Center, "We, the Students" http://www.supremecourthistory.org/05_learning/subs/05_a.html

University of Missouri-Kansas City Law School, Exploring Constitutional Conflicts, Free Speech Rights of Students http://www.law.umkc.edu/faculty/projects/ftrials/conlaw/studentspeech.htm

Irons, Peter. The Courage of Their Convictions. (New York: The Free Press, 1988.)

Johnson, John W. The Struggle for Student Rights: Tinker v. Des Moines and the 1960s. (Lawrence, Kansas: University of Kansas Press, 1997.)

La Morte, Michael W. School Law. (Massachusetts: Allyn and Bacon, 1990.)

Reutter, Edmund E. Jr. The Supreme Court's Impact on Public Education. (Bloomington: Phi Delta Kappa and the National Organization on Legal Problems of Education, 1982.)

Zimring, Franklin. The Principle of the Thing: Goss v. Lopez, Students' Rights, and Litigation in the Interest of Children (out of print but check with online bookseller for used availability)

Interdisciplinary Links

Community Service: Many student rights and responsibilities documents were drafted in the wake of Goss v. Lopez, but they may not be current in the wake of new technologies, including computer, Internet, and cell phone use. In conjunction with the student government, a committee could be created to draft revisions to the existing student rights and responsibilities codes and to submit the suggested revisions to the school board for consideration.

Photography: Some of the most effective advocates for juvenile's rights have been photographers, such as Lewis Hine and Jacob Riis, who crusaded against child labor. Student photographers may wish to create a portfolio of photographic images to advocate improvement in some aspect of juveniles' rights.