Hastings Constitutional Law Quarterly


Jessica Moy


Student blogs, social-networking sites, YouTube, and the Internet blur the line between high school students' public and private selves. Amid a world of rapid technological development and cloaked in the anonymity of cyberspace, cyberbullies are emboldened to utilize particularly cruel, and often psychologically damaging, tactics to victimize their peers. This Note examines the way in which the Supreme Court's decision in Morse v. Frederick has affected and changed the way lower courts evaluate the reach of school disciplinary authority in student Internet-posting cases and how the concept of what constitutes "on-campus" and "off-campus" activities has evolved over time. In light of the confusion and splintering of lower court decisions after the Morse ruling, I propose two alternative solutions to the conundrum presented by student Internet-posting and cyberbullying that courts might consider in the alternative.