Douglass v. Londonderry School, et al

2005 DNH 019
CourtDistrict Court, D. New Hampshire
DecidedFebruary 14, 2005
DocketCV-04-424-SM
StatusPublished

This text of 2005 DNH 019 (Douglass v. Londonderry School, et al) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Douglass v. Londonderry School, et al, 2005 DNH 019 (D.N.H. 2005).

Opinion

Douglass v . Londonderry School, et al CV-04-424-SM 02/14/05 P UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Blake S Douglass, a minor, By and through his next friend and father, J. Sherwood Douglass, Plaintiff

v. Civil N o . 04-424-SM Opinion N o . 2005 DNH 019 Londonderry School Board, et a l . , Defendants

O R D E R

Blake Douglass, a senior at Londonderry’s public high

school, challenges editorial decisions that have effectively

limited his ability to express his individuality in his yearbook

photograph. The basic legal question presented is whether the

United States Constitution limits editorial authority over

school-related publications and, if s o , to what extent. Before

the court is Blake’s motion for preliminary injunctive relief.

Defendants object.

Blake argues that he is entitled to control the form,

content, and presentation of his photographic portrait in the

senior section of the 2005 Londonderry High School Yearbook. Or,

viewed from a slightly different perspective, he claims that school officials may not lawfully refuse to publish the senior

portrait he submitted merely because they disapprove of the

“message” they think readers will take from i t . Blake insists

upon publication of a yearbook photograph that shows him dressed

in trapshooting gear and holding a shotgun broken open over his

shoulder, in a safe fashion. He points out that, in the past,

other students were permitted to pose with items expressing their

hobbies or interests, such as athletic equipment, cars, and

musical instruments. Accordingly, he claims that the refusal to

publish his chosen photograph in the senior portrait section of

the yearbook amounts to unconstitutional viewpoint

discrimination, in violation of his First Amendment rights.

Blake’s lawsuit seeks preliminary and permanent injunctive

relief that would compel school authorities to publish his chosen

photograph in the senior portrait section of the yearbook. But,

as will be discussed, based upon the pleadings, exhibits, and

testimony presented at a hearing, he has not established (and

perhaps cannot establish) the necessary prerequisites for

equitable relief. That i s , he has not demonstrated a likelihood

2 of success on the merits of his constitutional claims and, in

fact, it appears unlikely that he will succeed on those claims.

Standard of Review

To obtain a preliminary injunction, Blake must establish

each of the following: (1) a likelihood of success on the merits

of his claims (either at summary judgment or at trial); (2) the

potential for irreparable harm if an injunction is not issued;

(3) that the hardship imposed upon defendants if they are

enjoined will be less than the hardship he will suffer if no

injunction issues; and, finally, (4) that issuance of an

injunction is consistent with (or at least not contrary to) the

public interest. See Ross-Simons of Warwick, Inc. v . Baccarat,

Inc., 102 F.3d 1 2 , 15 (1st Cir. 1996).

Findings of Fact

At the hearing on his motion for preliminary injunctive

relief, Blake called two witnesses: his father, J. Sherwood

Douglass, and the principal of Londonderry High School, James

Elefante. Defendants did not call any witnesses, but did cross-

examine those called by plaintiff. Based upon the testimony and

3 documentary evidence presented at that hearing, the court makes

the following findings of fact.

Blake Douglass is a senior at Londonderry High School and an

avid trapshooter. The high school does not sponsor or support an

organized trapshooting team or club. Accordingly, Blake pursues

his hobby independently. In late summer of 2004, Blake went to a

studio used by many local students for yearbook pictures, to have

his senior portrait taken. He decided to pose for his senior

portrait in dress that communicated his keen interest in sport

shooting; he wore trapshooting attire, including a pocketed

shooting vest with what appear to be two shotgun shells in his

vest pocket, and he crouched on one knee, with his Ruger shotgun

safely broken open over his shoulder. At some point during the

session, the photographer suggested that Blake might want to pose

for some additional pictures, without the shotgun, noting that a

photo including a firearm might not be deemed appropriate by

yearbook officials. Blake did s o .

Alerted by the photographer’s comment about the potentially

controversial nature of his senior portrait, Blake’s mother

4 contacted the yearbook faculty advisor, M r . Juster. She

described the photograph to M r . Juster, who told her, based on

her description, that he did not believe the yearbook would agree

to publish the photograph. Blake’s mother then asked if she

could meet with M r . Juster, to show him the photograph before any

decision was made regarding its propriety. M r . Juster agreed.

But, after seeing the photograph, Juster affirmed his initial

impression and told Mrs. Douglass that he thought the photo was

inappropriate for the senior portrait section of the yearbook.

Mr. Juster also told Mrs. Douglass that Blake could discuss the

matter further with the school’s principal, M r . Elefante, if he

wished.

Blake did take the issue up with M r . Elefante. M r . Elefante

also reviewed the photograph and explained that, while he had

only recently assumed the role of principal, and was not an

active participant in editing or laying out the yearbook, his own

initial impression was that the photograph was inappropriate for

publication in the senior portrait section. But, he told Blake

that before any final decision would be made regarding

publication, he would have to consult with the yearbook’s

5 editorial staff. Blake’s parents then retained legal counsel.

Subsequently, M r . Elefante met with Blake’s parents and their

legal counsel, and reiterated the same views he had shared with

Blake. Elefante did concede that if the same photo were

submitted, but without the shotgun resting on Blake’s shoulder,

he would have little concern about publishing it in the senior

section of the yearbook.

In an effort to persuade school officials that the

photograph of Blake with the shotgun should be published in the

senior portrait section, Blake and his parents reviewed

Londonderry High School yearbooks from the past twenty years or

s o , collecting photographs in which students were engaged in

seemingly violent, unlawful, and/or vulgar behavior (e.g., posing

with weapons or simulated weapons, making offensive gestures,

referencing use of alcohol by minors, e t c ) . No doubt, their

point was that Blake should not be treated differently based on

the content of his photograph, which was fairly benign when

compared to some that had been published in the past.

6 School officials remained unpersuaded, noting that the

yearbook reflects current standards and values of the community,

and that those standards had evolved since the 1980s and even the

1990s. School officials also told the Douglass family that they

did not want students to use their senior portraits to advocate

politically charged positions or evoke divisive issues in the

community.

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