interest in teaching students the boundaries of socially appropriate behavior.” Id. at 681, 106 S.Ct. 3159. Schools are not prevented by the First Amendment from encouraging the “fundamental values of ‘habits and manners of civility,’ ” id., by “insisting that certain modes of expression are inappropriate and subject to sanctions.” Id. at 683, 106 S.Ct. 3159. And “[t]he determination of what manner of speech ... is inappropriate properly rests with the school board.” Id. Accordingly, Fraser establishes an exception to Tinker’s disruption requirement. Under Fraser, the banned school speech need not meet Tinker ’s disruption requirement; rather, speech in school can be banned if it is lewd, vulgar, indecent, or plainly offensive. Id. at 685, 106 S.Ct. 3159; see also Saxe, 240 F.3d at 213 (<HOLDING>); Boroff v. Van Wert City Bd. of Ed., 220 F.3d
holding that first amendment barred school from punishing student for vulgar myspace post concerning principal be cause it was offcampus speech recognizing obscene and indecent have different meanings and indecent speech may be regulated under some circumstances without transgressing the first amendment holding that university violated first amendment by expelling student for printing indecent newspaper despite student code prohibiting indecent conduct or speech holding that under fraser there is no first amendment protection for lewd vulgar indecent and plainly offensive speech in school recognizing school officials ability to act for the protection of minors from exposure to vulgar and offensive spoken language