Starr noted that in "Tinker" there was no written policy; it was an issue of "standardless discretion" being exercised. That case was said to be concerned with school disciplinary actions "casting a pall of orthodoxy to prevent the discussion of ideas". Justice Souter remarked that 'Bong Hits 4 JESUS' "sounds like just a kid's provocative statement to me". Starr responded by saying "the key is to allow the school official to interpret the message as long as that interpretation is reasonable."