D.J.D. v. Madison City Board of Education

In 2017, D.J.D., a high school student in Madison, Alabama, posted a rap video on Snapchat featuring violent lyrics that alluded to a school shooting and named specific classmates. School officials learned of the video and, deeming it a serious threat, suspended D.J.D. and later expelled him. D.J.D., through his father, sued the Madison City Board of Education in federal court, alleging violations of his First Amendment free speech rights and due process. On September 7, 2018, the U.S. District Court for the Northern District of Alabama granted summary judgment in favor of the school board. The court analyzed the off-campus speech under the Tinker v. Des Moines standard, focusing on whether the speech constituted a true threat and whether it was reasonably foreseeable that it would reach the school and cause a substantial disruption.

The court ruled in favor of the Madison City Board of Education, holding that D.J.D.'s Snapchat video was a true threat outside the protection of the First Amendment. The school's decision to expel him was justified as a reasonable response to foreseeable substantial disruption under Tinker.

Whether a student's off-campus social media post containing violent and threatening language constitutes a "true threat" unprotected by the First Amendment, and whether a public school's discipline of the student for such speech violates the right to free expression.

The case underscored the ongoing tension between student free speech and school safety in the digital age. It reinforced the principle that truly threatening off-campus social media posts can subject a student to school discipline, providing guidance for educators navigating the boundaries of authority over online expression.