The following excerpt is from Pico v. Board of Ed., Island Trees Union Free School Dist. No. 26, 638 F.2d 404 (2nd Cir. 1980):
Of course actions of school officials tending to suppress ideas must be sufficiently specific and serious to trigger First Amendment inquiry. Cf. Aebisher v. Ryan, 622 F.2d 651 (2d Cir. 1980). To regard every disapproving comment as a potential First Amendment violation would unduly intrude upon the prerogatives of the school authorities. A different situation is presented, however, when school authorities take clearly defined and carefully planned action to condemn an idea, especially when such action is taken with respect to an entire school or school district. The implication of such action is unmistakable, and its inhibiting effect is likely to be significant.
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