The need for research on academic freedom as it applies to the K-12 level is addressed. The existing literature in the area of academic freedom, while often critical, rhetorical, and prescriptive, never calls for research. Indeed, there are very few examples of research in this area. Two separate ERIC (Educational Research Information Center) database searches were conducted. Only five research-based articles on academic freedom were found. The following questions are submitted as ones whose answers are fundamental to improving academic freedom policies and practices in support of citizenship education: (1) What conditions in schools and school districts contribute to an environment that supports the study of controversial issues? and (2) What conditions in schools and school districts contribute to the successful resolution of protest cases? The use of naturalistic inquiry in the area of academic freedom and controversial issues at the K-12 level is advocated. Included in the two appendices are interviews with two secondary social studies teachers. (BZ)