Within the Tinker ruling, the irresolvable conflict in public schooling is laid bare: government must not curb free expression—see the First Amendment—but public schools, which are government institutions, sometimes must fetter speech to effectively educate. For instance, the Court wrote, “Clearly, the prohibition of expression…at least without evidence that it is necessary to avoid material and substantial interference with schoolwork or discipline [emphasis added], is not constitutionally permissible.”
As the Battle Map, an interactive database of values- and identity-based conflicts in public schools reveals, the need to maintain order is just one concern among many that has spurred public school officials to restrain speech. Administrators have also curbed expression they feared would render a school inhospitable, even threatening, to students from minority groups. They have spiked articles in student newspapers they thought were unfair to their subjects. They have punished speech by teachers that appeared to be political pronouncements. And the list goes on.
Many—perhaps most—peoples' sympathies likely lie with students and teachers more than school officials. Hopefully everyone's first reaction is that government must not censor speech. But these other concerns—disruption, marginalization, captive political speech—are also utterly understandable worries. For instance, as Justice Black wrote in his dissent, the armbands that the Tinker students donned to protest the war in Vietnam really did disrupt education: