In Settle v. Dickson County School Board, 53 F.3d 152 (6th Cir. 1995), a federal appeals court ruled that a public junior high school teacher had not violated a student’s First Amendment rights by attempting to prevent her from writing a research paper on the life of Jesus Christ. The decision highlights the principle that teachers have broad authority to manage classroom content and assignments.

Brittany Kaye Settle, a student at a junior high in Dickson, Tennessee, received a zero on her research paper on Jesus when her teacher Dana Ramsey refused to accept it. Ramsey believed that it would be difficult for her to evaluate Settle’s paper and that Settle should select another topic. Ramsey allegedly also told Settle that schools could not allow papers on religious topics.

A federal district court rejected Settle’s lawsuit, and a three-judge panel of the Sixth Circuit Court of Appeals agreed unanimously. In the opinion for the appeals court, Judge Gilbert S. Merritt wrote that “federal courts should exercise particular restraint in classroom conflicts between student and teacher over matters falling within the ordinary authority of the teacher over curriculum and course content.” Merritt also noted that “learning is more vital in the classroom than free speech.” In a concurring opinion, Judge Alice Batchelder reasoned that the case did not raise a constitutional question. Settle appealed to the Supreme Court, which denied review.

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