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2009 Cyberlaw Updates

 

Last Updated: April 17, 2009

 

Headlines Links

(Click the header links below to view full summaries; blue headers indicate postings since our last e-law listserv update.)

 

U.S. and 4th Circuit Cases & News (NC, MD, SC, VA, WV)

CyberSafety:  Overturned law to protect children from online pornography rejected by Supreme Court 

 

North Carolina Cases & News

CyberSafety—Social Networking:  N.C. sex offenders identified and removed from social networking site MySpace 

 

Legal Updates: Other Jurisdictions

CyberSystems—E-Mail:  New Jersey court bars school board candidates from soliciting support via school system e-mail

CyberSafety—Sexting:  Court precludes criminal charges against student for sexting pictures through her cell phone

CyberSafety:  Wisconsin teachers firing for viewing pornographic images on-line at school upheld by state court of appeals

CyberSpeech—First Amendment:  California community college may restrict Internet use on library computers to educational and employment uses

CyberSpeech—Privacy:  Connecticut court determines principal had reasonable expectation of privacy in her school email account

CyberSpeech—First Amendment:  Fake teacher and school administrator MySpace pages posted by students not protected as parodies

 

Other News

CyberSafety—Privacy:  Felony child pornography charges for teen sexting provokes controversy

CyberSafety—Social Networking:  As troubling online video postings of teen violence increase, schools contemplate how to fight back

 

U.S. and Fourth Circuit Cases and News

(Affecting schools in North Carolina, Maryland, South Carolina, Virginia, and West Virginia)

 

CyberSafety:  Overturned law intended to protect children from online pornography rejected by Supreme Court.  Mukasey v. ACLU, No. 08-565 (U.S. Jan. 21, 2009).

The Child Online Protection Act (COPA), created and approved by Congress over 10 years ago, was intended to prevent minors from accessing harmful content via the Internet.  In early 2009, though, the Supreme Court effectively quashed COPA by refusing to hear an appeal from the Third Circuit Court of Appeals which struck down the Act as unconstitutional.  The Third Circuit determined the law was a violation of the First Amendment and that Internet filter and other parental-control technologies constituted less restrictive means and, therefore, of less threat to free speech)to protect children from online harm.  Read the 3rd Circuit decision.

 

 

North Carolina Cases & News

 

CyberSafety—Social Networking:  N.C. sex offenders identified and removed from social networking site MySpace.

In response to a subpoena issued by North Carolina Attorney General Roy Cooper, the social networking website MySpace has turned over the names and e-mail addresses of 2,116 convicted North Carolina sex offenders found to be using the site.  In addition, MySpace has removed the individuals from the site.

This move is significant because a new state law (effective Dec. 1, 2008) prohibits sex offenders from being active on websites where children are also active.  Consequently, Attorney General Cooper is forwarding the information he received to state law enforcement agencies for further action.  Read the story. 

 

Legal Updates: Other Jurisdictions

(Cases not binding in the Fourth Circuit)

 

CyberSystems—E-Mail:  New Jersey court bars school board candidates from soliciting support via school system e-mail.

 

According to a recent news report, a New Jersey state court issued a cease and desist order to two board candidates from using school system e-mail server to solicit support from system employees.  The candidates purportedly obtained the staff e-mails from the school web site.   The systems technology policy prohibits staff from using the systems network to assist with a campaign for election of any person to any office or for the promotion of or opposition to any ballot proposition.  The provision applies to anyone using the systems mail server.  Source: Asbury Park Press, Mar. 24, 2009.

 

CyberSafety—Sexting:  Court precludes criminal charges against student for sexting pictures through her cell phone.  Miller v. George Skumanick (M.D.Pa. Apr. 3, 2009)

 

A judge ordered a Pennsylvania district attorney from filing criminal pornography charges against female students after they sent pictures of themselves clad in their underwear via their cell phones.  Officials at the girls school found pictures in several student cell phones of "scantily clad, semi-nude and nude teenage girls and turned the phones over to the district attorney.  The parents, in this case, successfully contended that the images did not constitute child pornography since they did not depict sexual activity or show the girls' genitalia.  The district attorney had demanded in lieu of being criminally charged, that the girls attend a "re-education" program and write essays about their improper conduct.  The parents successfully argued that such a requirement violated their due process rights to educate their children.  Source: Westlaw Watch, April 16, 2009.  Read The FirstPost article.

 

CyberSafety:  Wisconsin teachers firing for viewing pornographic images on-line at school upheld by state.  Cedarburg Educ. Assn v. Cedarburg Bd. of Educ.,  No. 2006CV501 (Wisc. Ct. App. July 23, 2008).

A Wisconsin public school teacher was fired for just cause because he used his school computer to view pornographic images at school.  The teacher appealed his firing and an arbitrator reinstated him because his 11-year employment record was otherwise clean and he used his office computer (as opposed to a public computer) to view the images.

However, the Wisconsin Court of Appeals overturned the arbitrators decision holding that a clean employment record with the school was not sufficient to overcome the strong public policy against immoral conduct in schools.  Read the case.

 

CyberSpeech—First Amendment:  California community college may restrict Internet use on library computers to educational and employment uses.  Crosby v. S. Orange County Cmty. Coll. Dist., No. G040033 (Cal. Ct. App. Feb. 18, 2009).

The California Court of Appeals upheld a community colleges policy which limited the use of library computers for accessing the Internet except for educational or employment purposes.  The court found this restriction did not conflict with a state statute prohibiting schools from punishing students for actions in violation of school rules that would otherwise be protected by the First Amendment because the schools library computers were not part of a public forum.  Read the case.

 

CyberSpeech—Privacy:  Connecticut court determines principal had reasonable expectation of privacy in her school email account.  Brown-Criscuolo v. Wolfe, No. 3:05CV01486 (Conn. March 9, 2009).

A Connecticut district court found that a school principal had a reasonable expectation of privacy in her email, including an email and attachment she sent to her attorney describing problems she was having with the school superintendent.  While the principal was on medical leave, the superintendent accessed the principals email account and forwarded the email and attached letter she had previously sent to her attorney to his email account in violation of her Fourth Amendment rights against unreasonable searches.

The court also found that the principals use of her computer to draft and send the letter was within the schools Acceptable Use Policy (AUP), which restricted use of school computers to professional or career development-related uses.  Additionally, while the AUP also permitted routine monitoring and maintenance of the computer system, the court did not believe the superintendents actions qualified as such.  Read the case.

 

CyberSpeech—First Amendment:  Fake teacher and school administrator MySpace pages posted by students not protected as parodies.  Barnett ex rel. Barnett v. Tipton County Bd. of Educ., No. 07-2055-JPM-dkv (Tenn. Jan. 26, 2008).

A group of high school students in Tennessee created fake Internet profiles for a teacher/coach and assistant principal at their school and posted them on the social networking site, MySpace. The profiles, which were accessible to the general public, contained sexually suggestive comments about female students that appeared to have been posted by the school employees.  The students claimed their websites were parodies and therefore protected by the First Amendment.  However, the court held that the profiles were not parodies because they were reasonably believable (in fact, the school received calls about the postings from concerned community members) and were not clearly exaggerated to enhance humor.

 

Other News

 

CyberSafety—Privacy:  Felony child pornography charges for teen sexting provokes controversy.

The phenomenon known as sexting, whereby teens send nude or semi-nude self-portraits via cell phone, has become more prevalent in the United States as cell phones with built-in cameras have become virtually ubiquitous.  Studies have indicated up to 20% of teen girls have sent or posted online revealing self-portraits.  In some jurisdictions, ambitious prosecutors have begun charging teens with child porn violations for sexting.  This has proven controversial because child porn charges are generally felonies and can result in teenagers obtaining permanent sex offender status. 

Prosecutors maintain such harsh penalties will convey the seriousness of the activity and quickly end the practice.  However, others view the criminal penalties as excessive for teens guilty of little more than poor judgment.  Opponents believe the incidents are best handled between parent and child, with parents exercising more control over the technology use of their children. Source:  e-School News, Feb. 5, 2009.  Read the story.

 

CyberSafety—Social Networking:  As troubling online video postings of teen violence increase, schools contemplate how to fight back.

YouTube and websites like it that allow users to post self-made video content have become repositories for a great deal of video depicting teen violence.  Some of the videos are created spontaneously when inevitable schoolyard fights break out, but more troubling are the videos that demonstrate premeditation, such as the beating of an unsuspecting teenager last year in Florida.  Officials fear these videos, which are quite popular online and can draw over a million viewings, are glamorizing violence and will encourage even more such behavior.

Ironically, some school officials have used YouTube as a tool to identify and punish students involved in fights that they might not otherwise have detected, a task made easier when identifying information like school names are posted with the videos.  A few schools have even added rules to their student policy manuals banning the recording of fights, with violators subject to punishment including suspension.

Finally, elected officials in Californias state government have proposed a new state law that would require YouTube and similar websites to actively search for and remove violent video content.  YouTube currently employs a user enforcement procedure whereby any user can flag a video for graphic or gratuitous violence.  The company then reviews flagged videos for rules violations and potential removal.  Source:  e-School News, March 19, 2009.  Read the story.

 

 

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