A student's right to freedom of expression was well-protected by twenty years of legal history until the United States Supreme Court in its 1988 decision Hazelwood School District, et al. v. Kuhlmeier, et al. sharply limited this right by approving a school district's censorship of a high school newspaper. Prior to the Kuhlmeier decision courts often used the "public forum" doctrine to uphold freedom of speech or expression. No censorship of expression occurring in a public forum is allowed. School publications were held to be public forums, and absent a showing of "material and substantial interference with school work or discipline" schools could not restrain the full First Amendment rights of their students. The Kuhlmeier decision held that the school newspaper was not a public forum because the school exerted control over it, and therefore the school's actions were justified as long as they were "reasonably related to legitimate pedagogical concerns." Although this decision has undone 20 years of federal law, some states have their own laws protecting the student press. These laws remain untouched by the Kuhlmeier decision. Furthermore, the Kuhlmeier decision arguably does not affect independent (non-school sponsored) publications at the secondary level or college publications. (Extensive footnotes are included.) (MHC)