Battles, Pedagogies, and Reflections on the First Amendment

Political Science Educator: volume 26, issue 2


This interview is the first installment in a Q&A series focused on education and politics. In November, Matt Evans (Northwest Arkansas Community College, Political Science Educator Co-editor) interviewed Will Creeley (the Legal Director of the Foundation for Individual Rights and Expression[1]) on the political struggle for First Amendment rights on college campuses. Creeley, a graduate of New York University Law School, has been at FIRE since 2006. He co-authored the book First Things First: A Modern Coursebook on Free Speech Fundamentals[2] (FIRE, 2019), edited various FIRE guides on civil liberties for college students, and authored court briefs in various First Amendment cases. 

Question: Is there a particular teacher, court case, experience, or issue that got you into First Amendment jurisprudence?

My father was a poet and I was cognizant at a very young age of the power of words to move people to center oneself in our shared humanity. As I grew older and realized I couldn’t write poetry myself, the idea of to protect the expression of others took on real attraction. It seemed like a useful way to spend some time and energy. I was also a hip hop DJ as a young man all through high school and then college and law school playing house parties and nightclubs, and then going on tour even a little bit throughout law school, both throughout the United States and as far away as Sweden. In doing that work, I likewise recognized the importance of protecting free expression. As a kid, I really liked Public Enemy, so recognizing the political power that words and an artistic expression can have was very attractive. Also [I liked] asking questions: Why did some cassette tapes or CD at the stores have parental advisory stickers on them? And my old man was friends with Allen Ginsberg and other poets at that time. I was aware of the fact that expression would sometimes be met with political condemnation, consequence, or even arrest. From an early age [it] seemed like the way my own attention was drawn was to voice and its ramifications.

Q: What does academic freedom, free speech, and free association mean for college students and faculty at public universities and colleges? What meaning does it have for private colleges and universities and colleges around the country? How do we see these rights violated?

 I think, first of all, if to the extent that we could take all these concepts together— and I think we can for conversational and conceptual purposes here—academic freedom, free speech and freedom of association: these rights are crucially important for college students and faculty at our public and private universities. Public universities are bound by the First Amendment to respect those rights. Private universities are not, but the vast majority of them promise students and faculty academic freedom and freedom of expression, and the ones that do not, we ask [that] they make that omission very clear to prospective students and faculty. All of those components of what I’ll call largely, more broadly, the search for truth and the search for understanding are only fully possible in an environment that respects, and in fact protects students and faculty’s right to debate and discuss political interference, without viewpoint discrimination, as it’s called in the First Amendment doctrine. And with really the broadest possible latitude to explore ideas where they may lead. I often remind students and faculty and also general consuls across the country that many of the ideas we now take absolutely for granted and think of as core bedrock truth were at one point contested, controversial, unwanted, or even heretical and those ideas gained the foothold that they did via competition testing, debate and discussion. If our universities are to fulfill their purpose as educational institutions. We know going back to a Socratic dialogue and even further that discussion amongst peers is a powerful way to determine the path forward, and I really want to emphasize that while each of these concepts—academic freedom, freedom of expression and freedom of association—have different contours, that taking them in concert together is absolutely appropriate and necessary when we’re thinking about the rights that must be protected in order to truly deliver on the promise of a liberal arts education.

Q: Could you expand a bit on free speech and private education?

We have lots of private institutions that we’ve seen over the years, and FIRE has been around since 1999… that will include flowery language, puffery you might call it, about their commitment to academic freedom or their commitment freedom of expression. When push comes to shove, for whatever reason—because the speech is critical, dissenting, or unpopular—it becomes convenient to ignore the language in the in the heat of the moment, and that’s deeply frustrating. I’ll give you a couple [of recent] examples…The case of Fordham University, which is a Jesuit institution but holds itself out as not quite secular, but certainly widely accessible and generally speaking a private university of no particular religious commitment. Fordham University denied a recognition to a chapter of students for Justice in Palestine on the basis that the group was divisive and polarizing, and when they were doing so, they ignored the fact that their promises of free expression did not permit any exception to group recognition because of “divisiveness,” or other grounds similar to that. The group filed suit within New York state court system and at the trial court level, before reversal, argued that the university had failed to follow its promises. The trial court agreed, and on appeal, the appellate court said that a private university has broad discretion to change its policies as it sees fit, so that that even if they had promised as much, they also could revoke promise, without being in breach or allowing for other procedural remedies. Some universities, in other words, try to have it both ways. They want to have the promise of free expression promptly featured but also reserved for themselves.

Q: Does academic freedom exist in different ways for students and faculty at community colleges?

Absolutely, this is a great question. I think there’s a real disparity…between the protection enjoyed by faculty both 10 years in adjunct at a four-year state schools and community colleges. Time and again, FIRE has found that community colleges play faster and looser with constitutional protections. Whether that is a result of administrative ignorance, reduced staffing levels, a lack of attention, lack of training, lack of care, that’s difficult to say, but we have found some of the worst abuses of freedom of expression [there]…We see faculty punished for protected extramural expression regularly by community colleges and also student expression regularly restricted or regulated unconstitutional ways at community colleges…

Q: Could you tell us about the heckler’s veto in this context? When is heckling legally defensible under the First Amendment on college campuses? What is the legal line for incivility? 

I’m assuming we’re talking about a public college campus. The line for “incivility”—when incivility crosses the line can be measured more precisely—is when uncivil speech at issue becomes punishable as one of the other categorical exceptions to the First Amendment. For example, you can be rude to folks on your college campus, to your peers. If you are, you cannot engage in discriminatory harassment as defined by federal anti-discrimination laws. That is, you could not deny one of your fellow students access to an educational opportunity to benefit by engaging in target expression that is so severe, pervasive, and objectively offensive that they simply cannot be reasonably expected to take advantage of the educational opportunities and benefits around them. So that is a high bar. But the First Amendment commands a high bar as well. With regard to a heckler’s veto, if I want to protest an unpopular speaker, somebody I disagree with that’s been brought to campus, I may do so, but I can only do so in a peaceful way. If I threaten violence as a means to silence voices…I should be subjected to full civil and criminal penalties. True threats are not protected by the First Amendment. With regard to disruptions, the legal line is roughly that the First Amendment protects speech that is unpopular with bottle throwers. As the Supreme Court memorably put it in Forsyth County vs. Nationalist Movement back in the 1980s, that threats of violence or disruption opposed by opponents of the speeches issue cannot be allowed to silence a protected speaker, no matter how unpopular his her or their ideas may be. We cannot hope to preserve the First Amendment as both a legal principle and a kind of a foundational democratic value if we allow threats of violence to short circuit speakers before they’re able to open their mouths, so we regularly remind universities of this principle. In a case, from the United States Court of Appeals from the sixth circuit, a few years back in Bible Believers vs. Wayne County, the Sixth Circuit dealt with the question of when law enforcement may remove a speaker whose remarks are causing such a disturbance or seem to be about to precipitate violence by because of opposition to the content of those, and the basic line is that the law enforcement can only do so as a last resort. Their first obligation should be to preserve the right of the speaker to speak, and that if violence is being threatened, the response is to address the folks making the threats and not to restrain the speaker.…we don’t allow threats of violence or disruption by opponents of the speaker to win the day.

Q: So you might say that someone could disrupt an event asking question, making the statement and let’s say the middle of a speech but so long as they don’t shut down the event and prevent the speaker from talking entirely, they could respond or ask questions when it’s not question time?

If you have a protest where your student group wants to protest the invited speaker, another student group and you will see a group of 10 then gets up in the middle of the speech and collectively walks out. Well, now we’re talking about disruption maybe 30 seconds, a minute. If it’s silent and otherwise non-disruptive and the event can go on. That’s likely on the constitutionally permissible side of things. Likewise, if you’re protesting outside the events or you’re peacefully protesting, you’re not disrupting the event, that’s generally acceptable. You’re not blocking access or egress from the event, fine. But if you are storming the stage, calling in bomb threats, pulling fire alarms, unplugging microphones, getting up and throwing things, and now you’ve crossed the line and sustained disruptions that do not permit a speaker to speak, and likewise the folks who want to hear the speech or ask questions…disruptive protest denies them those opportunities as well. That’s not protected. If I go to a speech with the sole aim of shutting it down and I proceed to do so because I’ve brought a bullhorn and nobody can hear the speech, and I won’t shut up. And that is the heckler’s veto in action, and that is not protected by the First Amendment.

Q: What about the situation we saw a few years ago at the University of Arizona where we saw students walking by a classroom where ICE agents were talking to a class and those student walkers yelled questions and slogans at the ICE agents for several minutes and then left? Are those hecklers protected by the First Amendment?

FIRE sided with the students. The students did not attempt to shut down the event, although they did disrupt it brief briefly, there’s a distinction there, so I think that’s an important one.

Q: Hypothetically, if a student in a class with a guest speaker disrupted an event momentarily by asking a question outside of question time or shouted some choice words, are they protected by the First Amendment? Is incivility less protected by the First Amendment in cases where students are enrolled in a class?

When students are in class, they do not possess First Amendment rights equivalent to those they enjoy outside of class. The classroom is the professor’s domain, and it is not a public forum. Generally speaking, a professor who imposed an academic punishment for a classroom disruption would not likely violate a student’s rights. Likewise, professors can require students to act with a degree of decorum while in class that a public university generally could not mandate outside of class.

Q: What advice do you have for professors facing incivility from students in the classroom?

Professors who consistently face disruptive incivility from enrolled students may impose academic punishments. As a general rule, I think progressive discipline accompanied by discussion and clarity as to expectations is best for all parties.

Q: What First Amendment rights do student government officers and student journalists possess? How are these rights violated?

Student government officers are distinct from student journalists, so I’ll take those in turn. When student government officers disburse mandatory student activity fee funding to student groups, they’re acting as the acting with the delegated authority of the university itself, so their expressive rights are not implicated and in fact because they’re acting as effective agents of the government. They are bound to respect the First Amendment’s prohibition of viewpoint or content discrimination. If I am a student government officer, I may not like the speech of the student group that is seeking funding, but I cannot deny them funding on the basis of viewpoint because I am acting with the authority of the government. I am distributing mandatory student activity fees that have been collected by the government and I have to be aware of the fact that the First Amendment constrains my ability to act in a viewpoint discriminatory manner I’m disbursing those fees. Student government officials obviously have their own personal right to speak. They can’t be subject to discipline within the office in the same way that other politicians can. That is, if the student government officer is censured by his or her peers, or impeached through the established impeachment process because of their speech, the censure nor the impeachment violates the First Amendment… Student journalists possess rights coextensive with their professional peers when they write for independent student publications. They cannot be punished or subjected to adverse action like funding reductions or removal from campus simply because their stories are unpopular with administrators of the student government and we routinely defend students who write for independence through newspapers. That is, student groups that are not produced as part of an educational program or department on campus when they face censorship for uncovering stories that either students, faculty, or university administrators.

Q: So how do we parse out extramural speech for student government, like a student government member belonging to the KKK? Do they have a right to belong to the Klan and be a member of student government? 

You don’t have a first right to be an elected official, and if you are an elected official, if you’re a student government member and your fellow students or members don’t like your extramural associations—constitutionally, if you were punished by the university itself, if you were suspended or expelled for your membership in a in a racist off campus group, that would raise First Amendment questions. If you are voted out of your student government by a group of your peers, that wouldn’t be a First Amendment issue.

Q: What about the ability of the school to take away a scholarship or financial resource for this membership? Or the ability of student government to make a presentation that’s contrary to the viewpoint of the school’s administration at a Board of Trustees meeting?

The First Amendment would protect those types of expressions and presentations.

Q: How do we parse out the rights of members of recognized student organizations to engage in free speech at public colleges?

That is the university by operating a recognized student organization scheme has opened up essentially a kind of limited public forum for its students, and in so doing has restrictions on its ability to dictate the viewpoints of those groups. In fact, it cannot dictate the viewpoints of groups, can’t punish those groups for their viewpoints, can’t deny them recognition and the attended benefits on account of their view. The Supreme Court…says that the universities recognition cannot be withheld because of a disagreement with their viewpoint or because of what other groups do they have to essentially recognize the student group, and if they violate the establishment rules then they can be punished, but they can’t refrain from recognizing it just out of some kind of apprehension that they may violate the rules.

Q: What can we say about the First Amendment rights of student journalists in the context of an independent paper versus a school-sponsored paper? Are there First Amendment differences between these two situations?

I think the ideal from my vantage point, as a First Amendment advocate is for student journalists to understand the importance of the amendment like freedom of expression and journalistic independence and integrity, whether they’re writing for an independent student newspaper or for a student newspaper that’s produced in association with, say, the journalism department at a state university…in reality your rights as the student journalists are more extensive and better established if you’re writing for an independent student newspaper, there’s an argument as we’ve seen. Unfortunately, some courts uphold this viewpoint that if you’re writing for a newspaper that is produced in conjunction with the university, and retain some control over the content of that newspaper as an exercise of pedagogical authority that because you’re engaged in an educational program, the university as an educator retains some editorial discretion. That’s an extension of a high school case called Hazelwood School District vs. Kuhlmeier by dealing with K12 student rights, where the court said that the censorship of a high school newspaper, produced in conjunction with the school’s curriculum as part of school classroom activities dissent should not offend the First Amendment because the school retained authority over it and could act in service of its legitimate pedagogical interests…[There’s] some buffer in response to the Hazelwood decision, both at the K12 level and the higher ed level, but that’s the basic idea. In other words, it gets a little trickier if there’s a relationship between the university and the and the paper.

Q: What does due process mean for public universities and college, as well as private universities and colleges? How do we see these rights violated?

FIRE also defends student due process rights. We take them very seriously. The basics of student due process are required in the classic formulation to have notice for some kind of hearing, and an opportunity to respond. The ways in which we see due process rights violated are many and in recent years most often have come within Title IX proceedings, that is, accusations of conduct that constitutes discrimination on the basis of sex. We’ve often responded when we see students who are punished summarily, who are punished without an opportunity to have full notice of the charges punished, without a fair hearing punished without an opportunity to ask questions of their accuser punished without the presumption of innocence, punished without a possibility of appeal…I think perhaps for me the most a memorable one of these cases involved a student at Valdosta State University in Georgia student named Hayden Barnes who was administratively Withdrawn from Valdosta State University. In other words, functionally expelled for his advocacy against the construction of a proposed parking garage on campus. Hayden was an environmental activist and had campaigned against the parking garage. He did not know that the president of the university was monitoring his Facebook account and when he posted a collage of protesting the planned parking garage on campus, the president unreasonably construed that as a threat on his life and over the objections of his administrative senior staff, the president ordered that Barnes be administratively withdrawn. That is, given 48 hours to leave campus without a notice or hearing and they slipped a note under his door and told him he had to get out of there…The court found it was well established that the students have procedural rights and that those rights were not followed here, and a reasonable administrator would have understood that you can’t simply kick a student off campus in this way Hayden Barnes had been kicked off campus.

Q: How do these First Amendment rights and due process rights play out on social media for students and faculty of colleges and universities? How do we see these rights violated?

We routinely see students and faculty punished for their expression on social media. Back in the mid-2000s FIRE president CEO Greg Lukianoff in and I warned in an article that the increased visibility of student and faculty speech for administrators would likely prove irresistible to those administrators and would grant them new access. Conversations that previously might have happened across the quad or in a dorm room and then just vanished into the ether. Well, now they were preserved, and visible for all to see and the instances of punishment for speech was accordingly skyrocket. I hate to say we were right. We’ve issued reports on our work defending student, faculty speech online, and I might venture a guess that much, if not the majority, of our work within the last five to ten years has involved student and faculty online speech in some way, but many of these controversies have their genesis online, so it’s a booming business when it comes to defending students that we teach online. I should say that there’s no social media exception to the First Amendment, and a student faculty speech does not lose any protection as a result of its place online. There’s no end run around the First Amendment simply because someone is posting things rather than saying them “in person.”

Q: What are some of the biggest misconceptions you hear from students, faculty, and general public about the First Amendment and due process rights in a college context?

The classic formulation is “hate speech isn’t protected by the First Amendment.” You know, if we had a quarter for every time I heard that that is a lasting misperception…Unless the speech at issue constitutes one of the categorical exceptions to the First Amendment it is protected by the First Amendment no matter how subjectively offensive one may find it, and no matter how objectionable some many or even most of us find it. That is a persistent misconception, and it’s an understandable one. We may ask ourselves, “why in the hell does the first event protect this awful speech,” you know? Then I think about Justice Chief Justice Roberts important point from Snyder v. Phelps involving the Westboro Baptist Church and their protest of the funeral of a dead American soldier. And I’m paraphrasing wildly here, but…he says as a nation, we’ve chosen a different course, and we recognize that speech is powerful and may feel deeply hurtful. But to protect public debate and to ensure that the ability of Americans to speak on matters of public concern remains at its freest we do not punish speech, even if it causes us great sorrow.

Q: How do you think faculty can teach undergraduate students these First Amendment principles and due process in the college context to students of differing abilities? How do you think some of these FIRE rights guides for students (on due process or the First Amendment) or reports (like the Stoplight Report) can be employed to teach these issues?

Pointing out that freedom of expression, rather than something to be feared, is part of our best democratic tradition here, even if it does feel painful, counterintuitive, harmful, and dangerous in the moment. So did many of the ideas such as equality between the races or quality between the sexes or the protection of a gay, lesbian, bisexual and transgender folks. You know those also counterintuitive to majorities and prior errors as well that that the First Amendment is in fact an agent of social change in that no matter ones, politics or political commitments, the First Amendment protects all of us. I think that that is a message especially in our polarized political moment that cannot be repeated enough, and so individual faculty if you’re teaching, you know, say geology it might be hard to work that in. But if you’re teaching geology, it might also be important to remember and teach your students and the importance of academic freedom, right? So if you find out something in geological studies that might prove unpopular politically inconvenient you still have the right to pursue that research or that scholarship or that teaching because the first amendment right to academic freedom and active freedom is an important and sustaining value in our democratic society. I just I think there are opportunities in teaching students that make clear that you understand. It’s not always easy, but it’s immensely valuable. Again, no matter the matter, your political commitments or even lack thereof, the First Amendment protects your right to think and speak for yourself and that is valuable. It’s not easy, but it is immensely valuable. And once it’s gone, it’s awfully hard to get back.

Q: What are you four favorite books on the First Amendment? What makes them worth reading?

Oh boy, I’ve had a great time this past year reading some of the more recent contributions to the First Amendment literature, and I think one of my absolute favorites should recognize a book by Amy Sohn, The Man Who Hated Women, Sex Censorship and Civil Liberties in the Gilded Age[3] (Farrar, Straus and Giroux, 2021). It is a real page-turner insofar as it discusses Anthony Comstock, the notorious anti-vice crusader and censor from the Gilded Age from basically the 1870s to 1920s. It explores both Comstock zeal to censor, but also the lives of the men and women who he silenced, arrested in some cases drove to suicide…it’s a lively, engrossing account of what censorship feels like in the moment, the motivations of the censor and also its impact on folks who believe deeply in a cause—in this book, most often the cause of suffrage, or birth control—and it’s just fascinating to see the relevance if the stories of the men, and women who suffered under Comstock then to the current moment. The way that there’s a real bridge, and even though it feels like perhaps another country altogether, it’s not very long ago, so you can see the distance traveled in our society because of the freedom of expression. A good way to get familiar with the case law and the American experience now with censorship would be Bob Corn Revere’s recent book, The Mind of the Censor and the Eye of the Beholder[4] (Cambridge, 2021)… [by] one of the nation’s preeminent first member attorneys. In fact, he was the litigator on that Hayden Barnes [case] mentioned before…It’s just a fascinating look at not only Anthony Comstock, but the popular reference to censor music television,  and a variety of speech including for example, comic books over the past 100 years and the common threads between those censorship efforts and the ways in which the First Amendment ultimately repels them and that also is a fascinating book with really rich detail and practitioners. One last [writer on the] benefit of freedom of expression, if not exactly the First Amendment, I recommend is Jonathan Rauch is The Constitution of Knowledge[5] (Brookings, 2021) and Kindly Inquisitors[6] (University of Chicago Press, 1995). In both of those books…the author makes the case for acting freedom of expression because of its knowledge-generating capacities and the way in which it furthers human understanding…Rauch is the genius at connecting the dots between, say, President Trump denouncing fake news to threats to unpopular scholarship in the Academy to the larger ways in which we understand the world around us, and the ways in which we advance together as a society.

Q: It seems there are a lot of cases and details to keep track of for students and faculty trying to translate complicated court doctrine and litanies of facts into increasingly shorter discussions with students with smaller attention spans. How do you avoid losing site of the forest with all the trees in thinking about the First Amendment? How do you make explanations about these rights parsimonious to the fleeting attention spans of students?

In my experience, emphasizing stories is very helpful. Law can seem complex—but at its most basic, law is just a way for humans to work out differences, and we’re all human. Find the stories and lead with the people involved. Happily, First Amendment jurisprudence includes so many compelling narratives—the bravery of the Barnette sisters, for example, and Mary Beth Tinker, too. On that note, I recommend two books: First, for faculty, check out the appropriately titled First Amendment Stories[7], a collection of essays from scholars exploring landmark First Amendment cases and the people involved in them in illuminating, absorbing detail. Second, for all audiences, check out Ian Rosenberg’s The Fight for Free Speech: Ten Cases That Define Our First Amendment Freedoms[8], which likewise takes a closer look at foundational First Amendment case law in an accessible, engaging way, with an emphasis on making the issues presented relevant to current cultural and political debates.

Q: What publications and authors do you follow to keep up with the First Amendment and due process rights? What do they do for you?

Yeah, so I think First Amendment News[9] run by Ron Collins. A longtime First Amendment scholar and author. It’s an excellent roundup of what’s happening and the First Amendment. I also think Reason[10] magazine and the Volokh Conspiracy[11] do an excellent job at providing updates on the First Amendment developments. I’m always kind of a subscriber to the idea that one should read the views of folks you disagree with so I kind of make a point of reading news from right, left and center…just to see how things resonate differently or similarly in different political contexts. So that I think it’s worth kind of widely reading. For example, one of the cases currently on the court docket that implicate First Amendment rights and the question of compelled speech at 303 Creative LLC v. Elenis, I want to read everybody from, you know, Slate[12] to the National Review[13] or the Washington Post[14] and the Wall Street Journal[15], etc. You know, just to get a range of opinions on First Amendment issues. I think that’s valuable. It’s also just frankly worth it to us to keep your eyes on SCOTUSblog[16] and read the various briefs that will come in on a high profile First Amendment case to get a sense of how different groups are reacting to different questions. It’s always fascinating to see the distance or the proximity of the position staked out at depending on the issues at hand, so you know, I just try and read as widely as one can. I think it’s probably the way to go.

Q: Do you think that academic freedom will be severely limited by some of these state regulations being discussed in Florida? How so?

Absolutely, we’re deeply concerned. In fact, we are litigating right now against the Stop W.O.K.E. Act[17] in Florida. We’ve filed a First Amendment challenge to the law in Federal District Court in Florida, and our oral argument just wrapped up a couple weeks ago. The state has taken the remarkable position that public university faculty do not have any cognizable active freedom rights. In fact, they are simply government employees and accordingly were told the government line and the government can control their speech. In that capacity, which is running conception of the role of public university faculty are awfully meager and depressing conception, and it’s radically at odds with decades of case law and our national commitment to academic freedom. So yeah, we’re deeply concerned, and we’re so concerned we filed federal lawsuits, so we were fighting it.

(Note that a federal judge has blocked the educational sections of the Florida law from going into effect between this interview and the publishing of this edition of the PSE newsletter.)

Q: Is there the possibility of other states following Florida and creating similar legislation?

I mean, that’s one of the concerns – if not challenged and stopped here we know we’ll see copycat legislation because there is a political appetite for it, like we’ve seen in the wave of anti-Critical Race Theory litigation.

Q: How does this law by Florida differ from past state laws that intruded on academic freedom?

The Florida law is remarkably brazen and clear in its affront to academic freedom. Indeed, the state’s defense of the law in court has underscored the threat it poses; the state has argued that faculty do not possess academic freedom, but merely act as functional mouthpieces for the state. As my boss Greg Lukianoff—FIRE’s President and CEO—says, it’s the most laughably unconstitutional attack on academic freedom he’s seen in two decades of defending campus rights.

Q: How do you see the Roberts court immediately and in the future impact of these rights on college universities and campuses?

Well, it’s very interesting that the Roberts Court has not had cases that explicitly deal with university student rights person yet, but the Roberts court may stretch on for quite a while in the future, so we shall see, and certainly some of the recent First Amendment decisions under the Roberts court have already impacted the first amendment landscape. I’m thinking of cases like Shurtleff vs. City of Boston or Matal vs. Tam, or, as I mentioned earlier, Snyder vs. Phelps and others, Minnesota Voter Alliance vs. Mansky or spend set of voters lines. Those cases have already had a substantial impact on First Amendment jurisprudence and we shall see how they continue to play out in the future


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Matt Evans, Northwest Arkansas Community College, Political Science Educator Co-editor 

Published since 2005, The Political Science Educator is the newsletter of the Political Science Education Section of the American Political Science Association. All issues of the The Political Science Educator can be viewed on APSA Connects Civic Education page.

Editors: Colin Brown (Northeastern University), Matt Evans (Northwest Arkansas Community College)


APSA Educate has republished The Political Science Educator since 2021. Any questions or corrections to how the newsletter appears on Educate should be addressed to

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