anti-authority student expressions through the use of cell phone and Internet technologies. There is a current policy vacuum relating to the extent of educators' legal responsibilities to intervene when such expression takes place outside of school hours and school grounds on home computers and personal cell phones. Students, teachers, and school officials are often targets of such expression. The author analyzes government and school responses by reviewing positivist paradigms. Her review of a range of legal frameworks and judicial decisions from constitutional, human rights, child protection, and tort law perspectives redirects attention to legally substantive and pluralistic approaches that can help schools balance student free expression, supervision, safety, and learning.

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