Leeb

May a school district censor material reasonably believed to contain an actionable defamation from an official campus newspaper? Yes.

I

David Leeb was the student editor of the Rancho Alamitos High School Newspaper, La Voz del Vaquero. Rancho is a public high school in the Garden Grove Unified School District, and the newspaper is faculty supervised.

On March 29, 1984, Leeb submitted the proposed April 1 edition to James DeLong, Rancho’s principal, for approval. The newspaper traditionally publishes an April Fool’s Day spoof. This one, for example, reported that rock star Michael Jackson was planning a concert at the school, the Los Angeles Raiders professional football team had scheduled a game with the Rancho squad, and spring break had been canceled for lack of interest. On the second page, a small disclaimer stated, “All the stories and announcements in this issue . . . are fabrications of the mind.” (Read literally, the disclaimer itself was, of course, a “fabrication!] of the mind.”)

On the third page an article appeared under the headline “Nude Photos: Girls of Rancho.” Prepared with the advice and consent of the journalism instructor, it was nonetheless the…