Alito agreed that Morse did not violate Frederick's First Amendment rights and emphasized in his concurrence that the holding only applies to students who advocate illegal drug use. He opposed the "educational mission" and "in loco parentis" analysis in favor of a "special characteristic" of schools that he identifies to be ensuring the physical safety of the students. Alito concluded that an exception must be made to the First Amendment free speech guarantee to protect the students; since according to Alito, advocating illegal drugs possibly leads to violence. But Alito insisted that this small reduction of what is protected by the First Amendment is "at the far reaches of what the First Amendment permits".