The Supreme Court has identified three types of fora for purposes of free speech analysis: (1) the traditional public forum; (2) the public forum created by government designation; and (3) the non-public forum. Board of Airport Comm’rs v. Jews for Jesus, Inc., 482 U.S. 569, 572, 107 S.Ct. 2568, 2570, 96 L.Ed.2d 500 (1987) (citing Perry Educ. Ass’n. v. Perry Local Educs. Ass’n., 460 U.S. 37, 45-46, 103 S.Ct. 948, 954-955, 74 L.Ed.2d 794 (1983)). Public schools generally, and elementary schools in particular, are not considered to be traditional public fora. Deeper Life Christian Fellowship, Inc. v. Board of Educ., 852 F.2d 676, 679 (2d Cir.1988) (citing Brandon v. Board of Educ., 635 F.2d 971, 980 (2d Cir.1980), cert. denied, 454 U.S. 1123, 102 S.Ct. 970, 71 L.Ed.2d 109 (1981)) (<HOLDING>). However, a state is free to open to the
holding that corrections officers mockpreaching and espousal of religious views did not constitute a substantial burden on inmates free exercise of religion holding that a high school is not a public forum thus precluding free airing of religious views recognizing a religious institutions right to free exercise of religion holding that a public high school newspaper was a limited public forum not a traditional or designated public forum because there was no evidence that the school permitted indiscriminate use by the general public quoting hazelwood sch dist v kuhlmeier 484 us 260 267 108 sct 562 98 led2d 592 1988 holding that mayor is a high public official