Main article: Bethel School District v. Fraser
In Fraser, a high school student was disciplined following his speech to a school assembly at which he nominated a fellow student for a student elective office. The speech contained sexual innuendos, but not obscenity. The Supreme Court found that school officials could discipline the student. In doing so, it recognized that "[t]he process of educating our youth for citizenship in public schools is not confined to books, the curriculum, and the civics class; schools must teach by example the shared values of a civilized social order." Recognizing that one of the important purposes of public education is to inculcate the habits and manners of civility as valued conducive both to happiness and to the practice of self-government, the Supreme Court emphasized that: "Consciously or otherwise, teachers--and indeed the older students--demonstrate the appropriate form of civil discourse and political expression by their conduct and deportment in and out of class." [6] Under the Fraser standard, school officials look not merely to the reasonable risk of disruption—the Tinker standard—but would also balance the freedom of a student's speech rights against the school's interest in teaching students the boundaries of socially appropriate behavior. Schools have discretion to curtail not only obscene speech, but speech that is vulgar, lewd, indecent or plainly offensive.
