Bullying has long been a concern for students, parents, teachers, and
school administrators. But technological advances—including the internet,
cell phones, and social media—have transformed the nature of bullying and
allow “cyberbullies” to extend their reach far beyond the schoolhouse gate.

The U.S. Supreme Court established that schools may regulate on-campus
speech if the speech creates a substantial disruption of, or material
interference with, school activities. However, the Court has yet to rule on a
school’s ability to regulate students’ off-campus bullying speech. This Note
examines how various courts have approached the issue, analyzes the
current circuit split, and ultimately proposes that schools should have the
authority to discipline students for off-campus bullying speech.