Student news organizations have long experienced various forms of censorship.
This qualitative pilot study (N=46) examines articles on college newspaper websites to explore how student news organizations cover issues of press freedom and censorship. The researchers used a grounded theory approach to explore common themes of coverage and potential differences between private and public institutions’ approach to such topics. The findings indicate there are four broad areas of interest: explanation of the role of journalism, industry challenges, censorship, and college-specific issues of press freedom and speech. This pilot study will serve to inform a larger content analysis.
According to the Student Press Law Center, censorship is “any restrictions on your publication’s coverage or operations by anyone who works for the school or is acting on behalf of the school (like student government officials)” (Dean 2021, para. 1). Outright acts of censorship can be seen, for example, when in 2013, The Fauman at Florida A&M University was “suspended from publishing, its adviser removed and its staff told they must reapply for their positions” (Gregory 2013). In a case study of different college newsrooms, it was found that “that administrators who engage in censorship appear to do so when the newspaper publishes unflattering coverage of the university” (Matlock 2021, 97).
However, censorship is not always obvious and can manifest in subtle ways. In a Q&A with College Media Review, then SPLC executive director Frank LoMonte identified newspaper theft and closure of academic programs as forms of censorship (Smith 2013). Student government representatives allegedly trashed student newspapers at Virginia Commonwealth University in 2020 (SPLC 2020), and a campus police officer was recorded throwing away copies of The Chimes, the student newspaper of Capital University, a private university in Ohio, in 2019 (Severino 2019).
While outright censorship may not be common, less obvious forms of control can be seen in budget cuts and disciplinary action against student journalists or advisers (Dean 2021).
Editorial control varies among student media outlets, and is often determined in part by funding. The College Media Association’s 2021 benchmarking survey indicates that student newsrooms are often funded by a combination of sources, with more than half of respondents indicating that they received some student fee funding, more than 30% getting departmental support, 40% reporting administrative allocations, and more than 60% bringing in some advertising revenue (CMA 2021). The same survey found that more than 10% of advisers indicated that they edited content or had decision-making ability over content—which is counter to the College Media Association’s Code of Ethics (CMA n.d.)
In general, the threat and potential for censorship is a constant source of concern and threat to student news organizations. Thus, it is of interest to explore how student journalists themselves report on issues of censorship, freedom of the press, and other related rights.
Therefore, the purpose of this study is to analyze how student news organizations report on and address such topics.
Student news organizations are not dealing with threats to student press freedom in a vacuum. A decline in support for mass media has been tied to a decline in trust in American institutions since the late 1970s, when 68-72% of people in the United States said that they trusted the mass media (Brenan 2021). The most recent Gallup data found that only 36% of Americans trust the media today, while 34% said they have no trust at all. Gallup reported this is the second lowest level of support on record, about four points more than during the 2016 presidential election. Media outlets were not alone, either, as Pew Research found that trust in government was at one of its lowest levels ever in 2015 (Pew 2021).
Donald Trump’s election in 2016 increased the climate of distrust in both the media and government as Trump successfully used rhetorical strategies to unite his followers and divide his opponents. Trump’s rhetoric not only attacked his opponents, but also the press (Mercieca 2020). For example, Trump threatened to weaken the protections of the First Amendment, promised to strengthen libel laws for use against journalists, and intimidated and threatened journalists, calling them the enemy of the people (Horwitz 2016; Gidda and Schonfeld 2016; Downie 2020). These threats were not limited to professional journalists, but student journalists often face threats to their press rights closer to home, which is why the Student Press Law Center declared 2019 the “Year of the Student Journalist” noting that “Student journalists have lesser First Amendment protections and are often subject to censorship, prior review, budget battles and other external pressures” (2019, para. 5).
There has been much work documenting instances of censorship of the student press. The Foundation for Individual Rights in Education (FIRE) found that “60% of student newspapers at four-year public institutions faced some form of censorship” in 2021 (Conza 2022, para. 2). In 2019, FIRE published a report detailing student media threats such as censorship demands, prior review, pressure on student media advisers, and newspaper theft (“Under Pressure” 2019).
Similarly, in 2016, the American Association of University Professors, the College Media Association, the National Coalition Against Censorship and the Student Press Law Center published a report documenting threats and hostility toward student media and press freedom. They noted that over a three-year period, more than 20 student media advisers reported attempts by university administration to censor the student press (AAUP et al. 2016). Significantly, the report found that these threats to student press freedom were evident at all types of institutions, including public and private institutions, religiously affiliated institutions, and community colleges.
Other research on censorship and the student press has addressed students editors’ and newspaper advisers’ willingness to self-censor based on intrinsic or extrinsic factors (Filak 2021; Farquar and Carey 2018; Filak and Reinardy 2009) or instances of censorship of the student press (see Bankes et al. 2002; AAUP et al. 2016).
Students at private institutions potentially face even greater threats of censorship, as it is well-established that students at public institutions are accorded greater First Amendment rights than students at private institutions. The constitutional guarantee of freedom of speech applies only to governmental actors or in instances where there is “state action.” State action is present when individuals, groups, or organizations perform a “public function” that has been exclusively the domain of the government (Flagg Bros., Inc. v. Brooks, 1978). In Rendell-Baker v. Kohn (1981), the Supreme Court definitively held that private schools are not state actors, and, therefore, the protections of the First Amendment do not apply. While the Rendell-Baker case concerned a private high school, the principles concerning state action are applicable to private colleges and universities as well. Thus, while public college students receive First Amendment protection, the free speech and press rights for students at private institutions tend to be determined contractually, in university bylaws or student handbooks, and administrators enjoy wide latitude in determining the scope of student press freedoms.
One of the first Supreme Court cases to discuss whether the student press has broad First Amendment protections is the Hazelwood School District v. Kuhlmeier (1988) case. Hazelwood examined whether it is constitutional for a principal at a public high school to delete articles that he deemed inappropriate from the student newspaper. The Court held that high school newspapers are generally not considered “public forums” and therefore do not receive broad First Amendment protections unless the school has opened up the forum for indiscriminate use by the public. In the Hazelwood case, the student newspaper was part of the school’s educational curriculum and was considered a “regular classroom activity” (484). Moreover, the newspaper was funded by the School Board and the teacher had editorial control over the paper. For this reason, the Court found that it reasonable for educators to make determinations about what content was appropriate and that the school had the legal authority to delete content deemed inappropriate or inconsistent with the school’s educational mission, so long as the school’s actions are “reasonably related to legitimate pedagogical concerns” (273). The First Amendment rights of high school journalists are, therefore, very limited and high school journalists lack broad First Amendment protections.
It is significant that the Hazelwood case dealt specifically with public high schools rather than colleges. In fact, in a footnote, the Court explicitly found that the Hazelwood case did not necessarily extend to colleges, noting that “[W]e need not now decide whether the same degree of deference (to school administrators’ decisions) is appropriate with respect to school-sponsored activities at the college and university level” (footnote 7). Many lower courts, then, have not extended the Hazelwood reasoning to colleges or universities (see generally Kincaid v. Gibson 2001).
However, in 2005, a federal appeals court explicitly extended the reasoning of the Hazelwood case to colleges and universities, holding that a college newspaper was not a public forum because the school provided funding and sponsored the activity (Hosty v. Carter 2005). The case held that university administrators may have the power to censor student newspapers when the university subsidizes the speech. The Hosty case caused great concern among free speech advocates and policy-makers, as it opened the door to broad regulation of the student press by university administrators. As a result, some states have statutorily extended free speech and press rights to students at both public and private colleges. California became the first state to extend broad First Amendment protections to private school students (see Cal. Ed. Code section 94376), students at community colleges (see Cal. Ed. Code section 76120), and also public college students (see Cal Ed Code section 66301).
The New Voices Movement, a grassroots movement that began in 2015, has advocated expanding the free speech and press rights to students at both public and private schools.
According to the Student Press Law Center, as of January 2022, 15 states have adopted legislation that broadened student press rights. These statutes offer varying degrees of First Amendment protections, yet the vast majority extend protections only to students at public high schools and universities. The notable exception is Rhode Island, which granted free speech and press rights to students at both public and private universities (see Rhode Island General Laws, Title 16, Chapter 109). Thus, only two states explicitly protect the speech and press rights of students at private universities.
While actual and potential threats to student press freedoms have been well-documented along with factors that may influence self-censorship, there is limited research on the ways in which the student media outlets themselves cover issues of censorship and free expression.
Understanding how the student media cover issues of censorship is important, as this may reflect what that the students themselves see as most significant. Moreover, the ways in which student media cover press freedoms has the potential to influence how the broader campus community perceives issues of censorship and the free press and whether audiences will perceive censorship and press freedom as a significant issue at all. Further, as the First Amendment rights of students at private universities are very different from students at public universities, this would suggest that student media organizations at private schools may cover issues of censorship and press freedom differently than those at public institutions.
As such, the researchers put forth the following questions:
- RQ1: How do student media organizations cover issues of censorship and press freedom?
- RQ2: Is there a difference in how student media at private and public institutions cover these issues?
The researchers identified all registered student publications of the College Media Association using a member directory. The authors removed duplicates, non-educational institutions, and programs without an online presence. Each remaining site was searched for specific keywords. Any articles that mentioned one or more of these terms that were published between January 1, 2018 and December 31, 2020 were collected for a total sample of 924 articles from 144 public four-year universities, 78 four-year private universities, and 19 community colleges.
For this qualitative pilot study, the researchers used a systematic sampling technique to construct a stratified sample (N = 46) based on institution type that represented 5% of the full data set. The pilot study sample included: 19 articles for “censor” and “censorship,” 16 articles for “First Amendment,” 9 articles for “free press”/”freedom of the press”/Press freedom/freedom of press, 0 articles for just “free speech”/”Freedom of speech and 2 articles for “free speech”/”First Amendment” that were found using both search terms.
The researchers employed a grounded theory approach to explore themes in the data. The researchers first used simple random sampling to select seven articles (about 15%), which the researchers, using the constant-comparative method, individually open coded. The researchers then discussed their open coding for commonalities and differences and developed 15 discrete codes. One article was recoded simultaneously by all researchers to confirm agreement. The remaining articles were evenly divided among the researchers, and each coded their subset using the agreed upon 15 codes. Using investigator triangulation, the researchers exchanged their subset of articles with each other and conducted a second round of coding. The researchers discussed these results and resolved points of contention through consensus, and then the researchers further collapsed the discrete codes into four general themes of journalistic coverage.
The researchers completed multiple rounds of analysis of the 46 articles in this pilot study. From the initial open coding, the 15 codes were:
- Industry challenges,
- Who is a journalist,
- Journalistic decision-making or explanation,
- Explanation of speech or press rights or history,
- Journalism mission,
- College journalism mission,
- General threat of censorship,
- Administrative threat of censorship (college),
- Acts of censorship (college level),
- Acts of censorship (non-college),
- Physical threat, harm, or death of journalists,
- Administrative expectations or reactions to negative coverage,
- Administrative or university support for student media,
- Donald Trump, and
- ‘Fake news.
Upon further review and discussion, these codes were collapsed into four dominant areas:
- the role of journalism,
- industry challenges,
- censorship, and
- college-specific coverage.
These areas will be discussed in greater detail below.
The Role of Journalism
By far, the most common topic among all the student media outlets and articles reviewed was the role of journalism, which included the codes of explanation and history of speech and press rights; journalism mission; journalistic decision-making or explanation; and who is considered a journalist. The most dominant theme among all newspapers, including newspapers at both private and public institutions, was an explanation of the rights guaranteed by the First Amendment. This received significantly more discussion than any other theme, including discussion of specific acts of censorship. Within this theme, the most common sub-theme concerned why the First Amendment is so important and what is broadly guaranteed by the First Amendment, as well as the marketplace of ideas. As The Et Cetera, a student publication of Dallas College Eastfield Campus (community college), noted in a 2018 editorial, “While there are many channels to express our right to freedom of speech, the right to a free press and free speech works hand in hand to hold politicians and the government accountable in the eyes of Americans.”
Often when explaining the First Amendment, other rights and protections were discussed in the context of the mission of journalism. Student media outlets indicated that the function of journalism is to tell the truth and that journalism must be a check on the powerful. For example, as students of Mt. San Antonio College (community college), wrote, “Our role as the free press is to keep the people informed by shining a constant spotlight on the truth, on the leaders people elect to lead them, and on the decisions those leaders take on behalf of the people.” There was also limited discussion about the importance of providing context for stories and that journalists should not guard or protect the public from information. The Monmouth Outlook (Monmouth University, 4-year, private) explained in a staff editorial that, “[journalists] are not responsible for guarding or protecting the people from the events of the world.”
However, in some cases, student newspapers were not just explaining free speech rights or their histories, but rather they debated the value of protecting all speech, including hate speech. For example, some writers suggested that the marketplace of ideas is not fair or equal. In a 2019 opinion piece from Seattle University’s The Spectator (4-year, private), a student wrote, “However, the marketplace of ideas does not account for an unequal society where some members have more privilege in getting to speak their thoughts, as well as to be taken seriously by the rest of society,” and argued that hate speech violates other constitutional guarantees: “Hate speech should not be protected by the First Amendment because it denies all Americans of their right to liberty promised by the Fourteenth Amendment, and prevents all Americans from becoming involved with the Democratic process.” Still other writers observed that some speech causes more harm than good, and the editor in chief of The Western Courier (Western Illinois University, 4-year, public) wrote, “Free speech is obviously a very important right that we have as Americans, but there is a line that must not be crossed.” Further, a letter to the editor published in Central Michigan Life (Central Michigan University, 4-year, public) noted, “Hate speech, though constitutional, is not harmless.”
Industry challenges subsumed the codes of more general challenges, fake news, and Donald Trump. Within this area, former President Trump’s attacks on the press emerged as one of the dominant themes. In many cases, the student newspapers discussed the former president as part of a warning of the erosion of a free press, in defending journalism, or when calling for more civil debate. Articles noted that Trump “shunned” the media, “attacked” the press, “lashed out at journalists,” and he claimed unfair treatment or censoring of conservative voices. For example, an editorial entitled “Staff Discusses Freedom of Press” from The Monmouth Outlook (Monmouth University, 4-year, private) reported that, “The current political administration has targeted various media outlets, claiming that they are ‘the enemy of the people.’” Similarly, The Miami Hurricane (University of Miami, 4-year, private) noted in an editorial that “The American press has also come under attack by our current president, who regularly tries to portray the media as an enemy to democracy, when in fact, it’s an ally.”
The code of fake news was often, but not always, linked to coverage of Trump, with reports in this theme focused on the proliferation of fake news, the threat it poses to democracy, and the role that Trump had in popularizing the term. The Commonwealth Times (Virginia Commonwealth University, 4-year, public), discussed the challenge in reporting real news if some audiences do not want to hear it and other audiences do not want to believe it. For example, they wrote, “Some criticized news programs for failure to be family-friendly — while others cried ‘fake news’ — insisting such a distasteful comment would never have come from the president’s mouth.”
Far less prevalent were more general industry challenges such as concern for the economic viability of the press in the digital age and the marginalization of the press, including the refusal of public figures to give access to the press or the loss of trust in media outlets.
Censorship incorporated the codes of general threat of censorship, non-college acts of censorship, and physical threat, harm, or death of journalists. General threats of censorship was a dominant theme in this category. Student journalists reported on this general threat from a variety of perspectives, including threats to the press, threats to individual free speech (both from the government and from private institutions), and threats to creative speech, such as books and music. For example, The Daily Emerald (University of Oregon, 4-year, public) warned that continuing threats to a free press “added to a growing list of recognizing the United States as an increasingly authoritarian state.” Whereas, The Daily Wildcat (University of Arizona, 4-year, public) reported that, “Our focus is largely on topics that will affect our democracy on a greater scale, but lately our guaranteed rights and freedoms have been routinely violated by the very government sworn to uphold them.” In terms of creative speech, in an opinion piece entitled
“Don’t you dare censor my comedy,” from Northern Arizona University’s Lumberjack student media outlet (4-year, public), the author critiqued political correctness and noted that “In comedy, sensitivity should be thrown out the window.”
Another theme was global threats to free speech and discussion of efforts to suppress the press in other countries. There was also broad discussion on a variety of issues, including the power of social media companies to censor speech and whether controversial speakers should be invited to campus. A column from The Daily Orange (Syracuse University, 4-year, private) stated that social media companies threatened free speech more than the government, stating that “Our discourse is filtered and approved by these private companies. University officials and a few thousand employees at Google, Twitter and Facebook ultimately decide what speech belongs in our political discourse and in our classrooms.”
However, in this particular pilot sample, there was an overall lack of overt cases of actual censorship, i.e., the prevention/suppression of publication or post-publication retribution that could create a chilling effect. In discussing censorship, it was often in the abstract or talking about censorship happening in other countries under more authoritarian governments. When discussing censorship, most articles revolved around concrete consequences of publishing information, such as the arrest of Julian Assange, the de-platforming of Alex Jones from InfoWars, or the banning of books.
When the student press covered issues of censorship and free speech specifically within the college context (college journalism mission, administrative threat of censorship, university support for press/free speech, administrative expectations/negative coverage, acts of censorship) several themes emerged. College journalists viewed their role as being a check on the actions of the university administration and that they had a duty to report the truth. For example, in an opinion piece in SAC Media (Mt. San Antonio College, community college, California), the author wrote, “Our newsroom takes a stand to be one of many defending the truth, shining that constant spotlight on it and the leaders who serve you, the student body, faculty and the rest of the community.”
Yet, despite the coverage analyzed herein coming from student publications, there was limited discussion of student press freedoms, though some coverage of larger issues of academic freedom and safety concerns. Notably, there was very little coverage of specific acts of censorship of the student press—theft of newspapers and budget cuts, which were more prevalent at public institutions than private ones. In a 2018 editorial in support of National Newspaper Week, the staff of The Prospector (University of Texas El Paso, 4-year, public), noted “In our own publication, we have dealt with budget cuts and have been asked to take down content or revise it to suppress the truth” but did not detail these incidents. In a more detailed editorial from 2019 entitled “Theft of newspapers an act of censorship,” The Golden Gate Xpress (San Francisco State University, 4-year, public), discussed the theft of copies of its publication, “The May 14 and May 15 theft of more than 2,000 Xpress newspapers was an assault upon our independent student voice and an important reminder of why free speech must be protected at all costs.”
While there was little discussion of specific acts of censorship, student newspapers did discuss general threats of censorship from the university administration or campus climates related to speech. For example, in the previously mentioned editorial from Syracuse University, the author also noted, “SU is no stranger to free speech controversies and is near the bottom of the list of almost every university free speech index published.”
Private vs. Public
In addressing the second research question—Is there a difference in how student media at private and public institutions cover these issues?—the largest variation in coverage was seen in the college-specific coverage area. Discussion of general threats of censorship were more common among private institutions. Private institutions tended to focus on speech policies, such as the restrictive nature of free speech codes, or on indexes ranking colleges and universities in free speech protections, or administrator statements that the student press should protect the reputation of the institution. On the other hand, at public institutions, there was very little discussion of administrative threats, with only one specific incident of administrative threat being noted in this pilot sample. At UCLA (4-year, public), The Daily Bruin was sent “a cease- and-desist letter for having UCLA on our flyer and having a bear – not the Bruin bear, just a bear – on our flyer, trying to prevent us from using it as advertisement.”
Student newspapers at public institutions also discussed administrative support for free speech rights, which was primarily policy focused, as opposed to specific acts of support.
Articles discussed current or proposed speech policies at their university or state-wide policies designed to protect free expression at colleges. For example, The Battalion (Texas A&M, 4-year, public) wrote a 2018 article, “Student Senate passes free speech resolution” in which the reporter noted, “The resolution contained an explicit declaration of support for the First Amendment, which quelled concerns about the Student Senate’s position on allowing free speech activities on campus.” On the other hand, at private institutions, there was virtually no discussion of administrative support for free speech on college campuses.
In one other, though less prominent difference, in this particular sample, it is notable that only public universities’ student media outlets used the word “racism” or “racist” when discussing free speech. No private university newspaper used the word in the sample. This came largely in the context of Trump and, at times, was connected to specific remarks, for example The Commonwealth Times noted, “The New York Times sparked similar controversy last week by publishing a ‘definitive list’ of instances in which Trump has done or said something undeniably racist. The compilation documents everything from Trump’s refusal to rent apartments to African Americans in the 70s to his most recent ‘shithole’ remark.”
These four dominant findings suggest that student media coverage did vary between private and public institutions, primarily when covering specific incidents of censorship or threat on their own campuses. Yet, by and large, when covering issues of press and speech freedoms, student media outlets were far more likely to discuss and explore the role of journalism in society and the rights and privileges afforded them.
Discussion & Conclusion
Overwhelmingly, student media coverage of issues of censorship was dominated by the potential for censorship or speech restrictions rather than actual incidents of censorship, though there were private and public institution differences in that coverage. That private institutions devote more discussion to general administrative threats to free speech is not surprising, given that student newspapers at private institutions do not have the same free speech protections as student newspapers at public institutions. The dominance of this coverage does suggest that issues of censorship and free speech are of concern to student journalists. This aligns with the findings regarding student journalists’ mission. Students saw the function of journalism as a check on the powerful and to report the truth. As such, they view the role of the student journalist as consistent with professional journalists.
Yet, the analysis revealed there is room to help both student journalists and audiences understand censorship and its impacts, as there were examples in which it became evident that there was confusion regarding what censorship is in its most basic form and who has the power to censor. There was also debate regarding how far free speech extends, particularly in the context of hate speech. Student journalists were reporting on the limits of speech in ways that considered other consequences, such as harm. Yet simultaneously, some student media coverage also speculated as to whether the United States is becoming less democratic.
With the dominance of coverage that examined free speech rights and censorship, these findings support advancing education and training in free speech, its legal protections, and its legal limits. In serving as campus publications, student news organizations recognized their ability to inform their communities, but they also serve a role in educating the campus community about what is happening both locally and nationally. Thus, it is important for student journalists to be educated in the rights of free expression to extend this understanding to audiences, including their own peers, who may be less familiar with their rights and protections. Stronger education in speech and press rights may prepare audiences to more fully exercise individual rights to free expression.
Limitations & Future Research
This research serves as a pilot study (N = 46) for a larger analysis of all collected articles (N = 924). As such, the sample of articles analyzed was limited and the findings are not intended to be generalizable. The findings of this qualitative study will be used to develop a codebook for the quantitative analysis of the full data set. In that content analysis, the authors will seek to identify common approaches to the topics of censorship, etc. by student news organizations.
However, neither this pilot study, nor future content analysis, has the ability to explore self-censorship or intent. Thus, future scholars should explore these topics in greater depths through other methods such as focus groups and interviews. Further, given the influence of Donald Trump, in the context of free expression, within this pilot sample, the researchers intend to explore whether student media coverage of free speech changed in light of the Trump presidency.
While the College Media Association is a national organization, not all student media operations are members and thus were not considered for inclusion in the study. Other scholars may wish to explore other avenues for identifying student media outlets for inclusion in related research. Additionally, future scholars may wish to compare student media coverage of such topics in different eras. The sheer variety of topics related to censorship and issues of free speech in this pilot sample—from creative expression to social media and beyond—provide many avenues for future exploration.
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- Title 3 Cal Ed Code section 66301 (2009).
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Kirstie Hettinga (Ph.D., The Pennsylvania State University) is an associate professor in the Communication Department at California Lutheran University. Her research addresses issues of accuracy and credibility in news media. She teaches media writing, editing, and content creation and serves as the faculty adviser to Cal Lutheran’s student newspaper, The Echo.
Ryan Medders (Ph.D., University of California, Santa Barbara) is a professor in the Communication Department. His research addresses the social and psychological effects of the media, including selective exposure to and credibility assessment of online news and information. He teaches courses in mass communication, research methods, political communication, and international media.
Sharon Docter (Ph.D., Annenberg School for Communication, University of Southern California; J.D., University of California Los Angeles School of Law) is a Professor of Communication at California Lutheran University. Her research examines the ways in which the regulation of communication technology impact freedom of expression. She teaches courses in communication theories, freedom of expression and legal issues and new media.