Saturday, April 27, 2013

Doninger v. Niehoff, et al (2d Cir. 2008) Moot Court Activity



Doninger v. Niehoff, et al (2d Cir. 2008)
                                                                          

Facts of the Case
This case comes from Lewis Mills High School, in the Connecticut Region #10 School District. Administrators barred a Connecticut high school student from running in a student election after the student criticized administrators online for their handling of a student festival. In the spring of 2007, Jamfest, a yearly music festival at a Connecticut high school, experienced a series of planning setbacks that threatened to postpone or cancel the event. When Avery Doninger – a junior and incumbent class secretary – was unable to meet with the school's principal, Karissa Niehoff, to talk about the event she and three other students sent a mass e-mail asking members of the community to speak to administrators about putting the event back on schedule. Doninger and Niehoff later had a discussion in the hallway, during which she says Niehoff informed her that the event had been cancelled.
That night, Doninger wrote a Livejournal blog post criticizing the school officials' handling of the issue. In the post, she called the school officials “douchebags” and asked her fellow students and their parents to complain to school superintendent Schwartz in order “to piss [Schwartz] off more” than the mass e-mail had.
In response to her blog post, the school barred Doninger from running for reelection as Class Secretary for her senior year. At the class election, school officials prevented a group of students from wearing “Team Avery” t-shirts. According to school principal Niehoff, the t-shirt ban was intended to prevent electioneering by candidates and supporters who could afford such merchandise.
Questions to Consider
1.      Did the school district violate the First Amendment rights of Avery Doninger, when they forbade her to run for student office, because of her offensive vulgar language?
2.      Did the Connecticut District make the wrong judgment when they ruled in favor of the school district?




Issues for Avery Doninger
1.      This action violates free speech

2.      The blog post was not written in school, it was written at home

3.      The district court erroneously concluded that the defendants did not violate plaintiff’s daughter’s first amendment rights, after she posted comments on a public internet website from her home. Because this was not “school speech” the defendants acted without authority by punishing for her protected speech.

4.      Even if the posting to the internet were to be treated as “school speech,” the defendants violated Avery’s first amendment rights because her speech contained a political message that neither caused, nor was likely to cause, substantial disruption to the educational process.

5.      The Connecticut Constitution’s protections for free speech are broader than those contained in the first amendment, and would prohibit the censorship of student expression that occurred here.

6.       The plaintiff’s daughter was treated differently than other similarly situated student leaders and sanctioned because the school principal disagreed with the constitutionally protected political message that she posted on a public internet website, in violation of the equal protection clause of the fourteenth amendment.


(Note: The Fourteenth Amendment made the Bill of Right Applicable to the States)






Issues supporting Karissa Niehoff and Paula Swartz
1.      Just because this blog was written off campus, it was about the school, so thus it has become a school issue
2.      This speech has caused disruption, and schools may banish speech that is disruptive to school
3.      In accordance with 106 S. Ct 3159 educators are permitted to exercise editorial control over school-sponsored activities, such as school publications and or theatrical productions, as long as their actions are reasonably related to legitimate pedagogical concerns (does this damage the learning atmosphere of the students)
4.      The Supreme Court has determined that public schools may take steps to safeguard those entrusted to their care from speech that can unreasonably harm the educational process
5.      The school has not retaliated by suspending or expelling the student, the school has just taken away the “privilege” for running for a student leadership position












Issues for the Judge to consider
A government official is protected by qualified immunity if his or her “conduct did not violate a clearly established constitutional right or if it was objectively reasonable for the [official] to believe that his conduct did not violate such a right.” A right is “clearly established,” Livingston continued, if it is “defined with reasonable clarity,” recognized by the U.S. Supreme Court or the 2nd Circuit, and “a reasonable defendant would have understood that his conduct was unlawful.”
Finding that Niehoff and Schwartz were entitled to a claim of qualified immunity in refusing to allow students to wear them. “We agree that a reasonable fact-finder could conclude that Defendants were mistaken in assessing the likely impact of the t-shirts and thus the permissibility of prohibiting them pursuant to Tinker,” Livingston wrote, “however, we conclude that any such mistake was reasonable.” Because the administrators’ decision was reasonable, qualified immunity should be extended, the court ruled. “The law governing restrictions on student speech can be difficult and confusing, even for lawyers, law professors, and judges,” Livingston wrote, adding, “‘School principals,’ as the Supreme Court has recently noted, ‘have a difficult job.

1.      Is it true that, if students, or staff brought up the blog post in school, does it mean that, this is now an issue brought unto school grounds?
2.      So am I protected by free speech, if I go a crowded public place and falsely yell BOMB causing a panic?
3.      Counsel given how busy courts are and everything we decide, why should we bother to hear this case, of basically a high school student not getting their way?
4.      When the Founding Fathers wrote the First Amendment, could they have been thinking of blogs such as these?
5.      What about a blog saying vulgar things about Taylor Swif.t that could be accessed from the school library computers?




CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED

U.S. Constitution, Amendment I
Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or right of the people to peaceably to assemble, and to petition the Government for a redress of grievances.

U.S. Constitution, Amendment XIV (14), Section 1
All persons born or naturalized in the United States and subject to the jurisdiction therof,
are citizens of the United States and of the State wherein they reside. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.

Conn. Const. Art. I, § 4
Every citizen may freely speak, write and publish his sentiments on all subjects,
being responsible for the abuse of that liberty.

Conn. Const. Art. I, § 5
No law shall ever be passed to curtail or restrain the liberty of speech or of the press.

Conn. Const. Art. I, § 14
The citizens have a right, in a peaceable manner, to assemble for their common good,
and to apply to those invested with the powers of government, for redress of grievances, or other proper purposes, by petition, address or remonstrance.

Title 42 U.S.C. § 1983. Civil action for deprivation or rights.
Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory of the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, . . .



Roles
Petitioner: Avery Doninger  
·         Head Counsel: facilitates and argues the case
·         Lawyer: argues the case
·         Paralegal: Prepares the case
·         Paralegal: Prepares the case
Respondent: Karissa Niehoff et al. (Region 10 School District)
·         General Counsel: facilitates and argues the case
·         Lawyer: facilitates and argues the case  
·         Paralegal: prepares the case
·         Paralegal: prepares the case
Amicus Curiae “Friend of the Court” (2 Amicus)
·         These people can also argue in favor of Doninger or Niehoff
Marshal of the Court
·         Head Law Enforcement Official of the Court
·         To call the court into order
·         Keep the time
·         Each party has a total of 5 five minutes

Time Allotment (14 Minutes Total)
·         Each party is allotted five minutes of oral argument
·         Doninger goes first- 5 minutes
·         Niehoff goes second- 5 minutes
·         Amicus has a minute each (2)
·         Doninger has the rebuttal for 2 minutes (Doninger’s Amicus can argue during this time)

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