According to free speech experts, censorship has spread in schools and colleges throughout the United States in recent years.

In 2011, the Minnesota State Supreme Court ruled in favor of the University of Minnesota to reprimand the off-campus speech of student Amanda Tatro for comments made on Facebook.

The court indicated this ruling was not due to the nature of the comments but their effect on the university's curriculum. Therefore, it became possible for the university to control a student's off-campus speech when it affected the reputation of the school.

"To the extent a decision is made regarding curriculum, the school should be able to make it," Missouri Press Association consultant Jean Maneke said. "To the extent a publication exists as public forum, there needs to be tolerance for free speech."

Tatro's Facebook comments focused on taking out her aggression in a science-mortuary class on a cadaver she named Bernie. Another student found the posts offensive and turned them over to the university. Families that donated cadavers called in concerns to the university, and Tatro was briefly expelled from class while police investigated her Facebook threats to stab an ex-boyfriend with medical equipment.

Tatro was venting in an off-campus forum thought to be outside the university's reach. Due to a lack of precedent for this case, the courts looked to the 1988 Missouri case Hazelwood School District v. Kuhlmeier involving high school students.

Before Hazelwood, the Supreme Court gave primary education students the benefit of free speech as long as it was not disruptive to the school environment. Hazelwood increased the level of censorship to control any action that caused "legitimate concern related to individual rights, safety or distractions to the school environment."

The Hazelwood decision allowed school officials to censor clothing, speech and even hair color. The 6th Circuit Court also recently applied the Hazelwood decision to permit a university to discipline off-campus speech it said affected school relations in the 2011 Minnesota v. Tatro case.

"The First Amendment document called this the chilling effect," said Charles Davis, University of Missouri's facilitator of the Media of the Future Initiative for Mizzou Advantage. "It makes people think twice about what they are saying."

A representative of the Student Press Law Center agreed that university students should not be judged on the same standard as high school students.

"We do not think that a university can justify giving its students no greater level of First Amendment protection than 14-year-olds in the ninth grade have," said Frank D. LoMonte, executive director of the Student Press Law Center. "College students are legally adults who are old enough to fully participate in the political process, and there should be no punishment for the content of their speech except for extreme circumstances, such as threats of violence."

Some professors are worried censorship of free speech and free expression is dangerous to the open-minded environment a student is supposed to learn in in a university setting. However, in the Tatro decision, the court bypassed the differences between the primary and secondary schools and focused on the one similarity between the two: both decisions concerned students.

"It's all about the extension of logic," Davis said. "So the courts ignore the age distinction, focusing instead myopically on the fact that whether high school or college, these people are first students, and so they elevate the student status over the age distinction. This is why Hazelwood is so dangerous: it established the broad rule that school-sponsored speech could be curtailed, which leads to this kind of mischief."

The 6th Circuit Court is not the only federal appellate court that has ruled in favor of university censorship. A circuit court granted Kentucky State University the right to pull a student yearbook for viewpoint comments in 1999, and the 6th Circuit Court granted Governors State University the right to censor the school newspaper for printing comments against the administration. The judges in both cases cited Hazelwood as a precedent in 2005.

"I think we need an anti-Hazelwood statute in the worst way," Davis said. "I think it would be fantastic to be able to repudiate this decision."

Although courts are giving universities more censorship power over student speech, University of Missouri adjunct associate professor of law Sandy Davidson doesn't believe it will have a huge effect on students.

"Just because an institution can engage in censorship or editing doesn't mean the institution would exercise the power," Davidson said.

Davidson said applying the Hazelwood decision is more about quality control than censorship. According to Davidson, anything that has a school stamp of approval on it becomes a quality issue.

However, Davis believes it might cause students to organize their own publications.

"School publications on campus might think hard about staying on campus or go independent, which is probably the last thing school officials want to happen," Davis said.

Regardless of the circuit courts' rulings, states such as Iowa, Arkansas and California have passed legislation similar to the College Campus Press Act, a 2008 Illinois law that specifically protects student journalists from administrative censorship at public universities in the state. Missouri does not currently offer this protection to students.

"If students in Missouri are alarmed that their state might be the next to fall under Hazelwood -- and they should be alarmed -- then they should get copies of the excellent laws on the books in places like California and Illinois and lobby their state legislators for the same level of protection," LoMonte said. "Students should also pressure their own schools to put rules on the books accepting that Hazelwood has no place on a college campus."