Student One did so, stating it was a “robable false alarm, just something sent me.” learned what Student One had done, he asked Student One to remove the meme from his Snapchat story. Student One had not shared any of the other messages between him and J.S. In turn, the Principal contacted the School District Superintendent and the police. One student reported the meme to his parent, who reported the meme to the High School Principal. Student One then posted the “I can’t take it anymore” meme to his personal Snapchat “story,” where it could be viewed by Student One’s Snapchat “friends.” It was available for approximately five minutes and seen by 20 to 40 other students. Commonwealth Court summarized the events that followed: I WILL TRY TO TAKE ALIVE AND TIE HIM UP AND EAT HIM.” The quote was attributed to Student Two, who was singing lyrics by Cannibal Corpse. then sent Student One a short video meme depicting Student Two playing guitar music into a microphone, captioned with: “IM READY AND MANY MORE WILL PERISH IN THIS STORM. wearing large “Elton John” glasses, apparently watching Student Two’s performance. I can’t take it anymore I’m DONE!” and a photo-shopped image of J.S. sent Student One a still photograph of Student Two singing into a microphone with the caption: “I’m shooting up the school this week. and Student One made fun of a classmate (Student Two), joking that Student Two looked like a school shooter because of his long hair and preference for wearing a “Cannibal Corpse” (a hard metal rock group that uses violent lyrics and graphic imagery drawn from horror fiction and films) tee shirt. Over the course of the conversation, J.S. and Student One using a private cell phone in his respective home. The memes were sent as part of an extended conversation over a period of 10 days, which took place after school, with J.S. Manheim Township School District expelled J.S., a student at Manheim Township High School, for two memes he sent to another student (Student One) via Snapchat, a social media platform. In this case, the Pennsylvania Supreme Court will consider a student’s due process right to cross examine witnesses at a public school student disciplinary hearing and the standard applicable to determining whether speech constitutes a “true threat.” Manheim Township School District, 231 A.3d 1044 (Pa. First Amendment: Threatening Speech Due Process in Public School Student Disciplinary Proceeding
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