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Understanding journalistic forum status


The 1988 Hazelwood v Kuhlmeier U. S. Supreme Court decision created a need for students and advisers to understand what forum status means for all scholastic media. This lesson defines the three types of forums and outlines what each could mean for students. The lesson also enables student journalists to choose which forum best meets their needs and take steps to create that forum. This lesson works best when used before the Creating an Editorial Policy lesson and after the Mission Planning lessons.



  • Students will examine the concept of the different forum models and what they mean for student expression.
  • Students will choose a forum concept that best meets their needs and explain their reasoning.
  • Students will develop arguments to explain what their forum choice means for the various communities they serve and create presentations that explain their choice.

Common Core State Standards



Determine the meaning of words and phrases as they are used in a text, including figurative, connotative, and technical meanings; analyze how an author uses and refines the meaning of a key term or terms over the course of a text (e.g., how Madison defines faction in Federalist No. 10).


Integrate and evaluate multiple sources of information presented in different media or formats (e.g., visually, quantitatively) as well as in words in order to address a question or solve a problem.


Develop the topic thoroughly by selecting the most significant and relevant facts, extended definitions, concrete details, quotations, or other information and examples appropriate to the audience’s knowledge of the topic.


Provide a concluding statement or section that follows from and supports the information or explanation presented (e.g., articulating implications or the significance of the topic).



100 minutes (broken out over two days)



Blackboard or whiteboard

Teacher laptop and digital projector

Internet access and student computers if available

Handout: Quick hit forum status

Resource: Questions about public forum status

Resource: Tweet 2: Choosing your forum status is like choosing the best medicine

Teacher Resource: Rethinking your forum status – why the correct wording is essential

Teacher Resource: R. O. Ex rel. Ochshorn v. Ithaca City School Dist.


Note: Students were to read Questions about public forum status, and Choosing your forum status is like choosing the best medicine as homework and before this lesson. The teacher resource links are extra background readings for the teacher.


Lesson step-by-step

1. Entrance ticket—10 minutes

As they enter, give students a blank sheet of paper on which they are to list the three types of forums with definitions that they read from their homework. They are also to choose which forum they feel would be best for their school and explain why. The teacher will collect the papers after 10 minutes.

2. Whole class discussion—25 minutes

Then, to gauge whole class response, poll students as to which type of forum they think is most important for their student media. Ask students why they voted the way they did. Guide discussion to ask students whether they considered concepts like student expression, censorship, decision-making and even fake news. During the discussion, the teacher should revisit and explain key points of each of the forum choices (closed, limited and open).

The teacher can also explain how the limited forum concept has changed in its meaning, depending how it is interpreted, because of the Second Circuit’s ruling in Ithaca. (Refer to the bulleted links above, including SPLC interpretation of the decision and a JEA Scholastic Press Rights Committee article, are for teacher use to help explain the significance of the change).

In short, Frank LoMonte, executive director of the SPLC, said the Ithaca court added a new definition of “limited” from what other courts had used, stating “limited” means (in the Ithaca decision) that student media content can be limited to certain subjects. Previous courts had consistently ruled “limited” meant schools could direct content to selected audiences. Various consulting groups that create model policies for schools have started using the new definition in their work.

Assessment—15 minutes

As discussion dies down, the teacher should re-poll the class as to which forum they best feel meets their needs and why. Note the reasons given for each forum type for the next day’s lesson.

Ideally, they should choose the open forum concept over the others because of its emphasis on student freedom of expression, critical thinking and decision-making, which lies in their hands.

If they do not choose the public forum model, have them talk about why they did not choose it and begin to list specific reasons for another day’s discussion.


Day 2 

Lesson step-by-step

1. Warm up—5 minutes

The teacher would check with students to see if any changed their minds and briefly discuss the three forum choices and what they mean. Explain that because the public forum is the best option for students, we will now use that forum as our standard and work to educate others about this forum status. Review the Quick Hit Forum handout (either as a class via a projector, or hand out copies to students) to facilitate the discussion and to use for the next portion of this lesson.

2. Whole class discussion—20 minutes

Explain that students will break into groups to develop a compelling presentation to inform various audiences about the forum status of their publications. Explain that is important to education different stakeholders about this status so others will be more informed about how the student publication operates and why. This can help prevent censorship, prior review, and even misunderstandings about the public’s perception of how the publication functions.

Students, in groups of 3, will develop a presentation to convince an audience about the importance of their chosen forum status. They should create some kind of multimedia component for their presentation that helps share their reasoning with the audience.

Types of audiences students could choose to address:

  • Student body
  • Faculty
  • Administrators
  • School board
  • Parents
  • Community service groups/city government
  • Local media outlets

3. Small group discussion—20 minutes

Group students according to which audience they would like to inform and present to. It is OK that there might be multiple groups addressing the same audience.

In small groups, students would develop ideas for:

  • How to reach out to their chosen community (forum, speak at a formal meeting, informally, etc.) and to plan means of contacting this audience
  • How to show why the public forum is the best option
  • How to stress the benefits of that decision not only to student media but to the targeted community
  • How to use different presentation techniques to get their message across (PowerPoint, Prezi, video, discussion group, etc).

Groups are not actually building the presentation (unless the teacher would like them to) but instead are considering how that presentation might operate and work. Each group would appoint a team leader who would take notes and share initial plans with the teacher and team members.


Assessment —30 minutes

Groups should present their plans, briefly to the class, and give feedback to each other. Assess:

  • Is the audience clear?
  • Are the presentation methods appropriate for the audience?
  • Are there engaging multimedia elements that would help strengthen the presentation?
  • Does the presentation seem structured and detailed enough to convey the students’ expertise in this topic?



The teacher or student editors could pair more journalistically experienced students in groups with those less experienced.