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American Identity and the Censorship of Literature in American Public Schools
M.A thesis
Writing, Editing and Mediating MA Name: Ramon del Rosario
student Number: 2360640 Pages:
42 word count:
16529
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Table of Contents
Table of Contents ... 2
Introduction ... 3
Chapter one: Censorship... 5
External Censorship ... 7
Internal censorship ... 12
Chapter Two: Court Cases ... 15
The Tinker principle ... 16
Island Trees v. Pico ... 20
Chapter Three: Advice and Book Discussion ... 22
Book Discussion ... 29
Conclusion ... 35
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Introduction
Censorship has been present in all form of communication – from print, radio and television to large parts of the internet. It has been a part of American society in both political and media circles, the latter of which mostly constitute public means such as radio and television broadcasts. It is not
surprising that censorship also occurs within the school system as children are generally perceived as susceptible to influences from their environments. Consequently, some teachers found themselves in the position where they have had to argue the literary value of chosen reading material in order to justify its use in the classroom. Often the arguments based on the literary merits of reading material are not enough to keep certain books in school. Instances of censorship of literature in schools have even led to involvement of courts in resolving disputes concerning censorship. These cases often touch on the subject of freedom of speech and the First Amendment which is an important part of American society.
This research has covered matters such as self-censorship practiced by school staff (Hartz 264) and the motivations behind acts of self-censor among school staff (Glatthorn 14). Attention has also been given to the external factors of censorship such as the groups and organization that are actively working towards the removal of books from school libraries and classrooms (Seiferth 151). This has resulted in literature intended to increase the awareness of the censorship threat amongst school staff and to show them – in advance – how to deal with censorship challenges (Sturm 6). While less research has been conducted with the aim to chart the censors and their motivations within a social context, a number of scholars have documented the categories most attacks on books fall into (Donelson 48). These included objections based on themes including sex, language, religion, respect of authority and morality (Swiderek 593). Scholars have looked into themes such as morality and obscenity as these are often central to arguments in favor of book banning (Ellenburg 514). Previous research in this field has also explored the role of religion in the censorship of literature; blasphemy, for example, has been a widely used argument against books that touch upon religious subjects (Edwards 39).
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American identity refers to the common values and beliefs that are regarded as inherent to American society. In the Article “American Identity and the Politics of Ethnic Change” Citrin, Reingold and Green discuss the national identity of the United States.
American identity refers to the common values and beliefs that are regarded as inherent to American society. In the Article “American Identity and the Politics of Ethnic Change” Citrin, Reingold and Green discuss American identity.
About the particular values that constitute the ideological conception of American nationality, there is little disagreement. From de Tocqueville on, the litany (Lipset 1964; Williams 1960; Huntington 1981; Pole 1967; Kohn 1957) is remarkably similar: democracy (republicanism, popular sovereignty), liberty (freedom), equality (of opportunity, in manners), and individual achievement (individualism, self-reliance). In sychological terms, the liberal version (Smith 1988) of the concept "sense of American identity" thus refers to the strength of emotional attachments to these symbols and to the institutions and practices that embody them (Delameter, Katz, and Kelman 1969). (1129)
This is a fitting definition of American identity to use in a conversation on the censorship of literature, as it touches upon particular values and emotional attachment to these values. It is not difficult to see how particular ideals can play a role in a censorship discussion.
Along with American identity the First Amendment is often at the center of the censorship debate, as it regards topics such as freedom of religion and expression, as well as the right to petition government, which can be found in this debate in one form or the other.
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The methodology for this paper consists of the study of a wide range of research into censorship in schools. This not only includes accounts from school staff, parents and activist groups, but also
analyses of court cases pertaining to the censorship of literature in high schools. The research process began by narrowing down possible sources based on their credibility and relevance. I also made sure that my selection of sources portrays both sides of the censorship discussion as well as the various groups involved in censorship. It is worth noting that this debate is so diverse, it would be wrong to reduce it to a mere dichotomy.
Chapter one: Censorship
A number of researchers have contributed to the discussion of censorship of literature in schools, providing insights based either on research, teaching experience, or activist ideology. One of these researchers is Michael Sturm, who provides a broad definition of censorship in his article “Censorship: Where Do We Stand?” in which he classifies the act of censorship as intentionally “prevent[ing] someone from viewing and/or hearing meaningful verbal, graphic, dramatic [materials], protecting a preferred belief or attitude” (5). According to Sturm, the techniques used in the act of censorship are as follows: interpretation (the particular way in which something is understood), redaction (the censoring or obscuring of part of a text), expurgation (the removal or leaving out of content that may be offensive), interpolation (the addition of content to a piece of writing), preclusion (to prevent something from happening), criticism (expressing disapproval of something), suppression (the act of suppressing something) and condemnation (expression of strong disapproval).
Another definition is provided by F.C. Ellenburgh in his article “Phantasy and Facts: Censorship & Schools.” Ellenburgh defines censorship as follows: “strictly, it means prohibiting expression. When legally enforcible, this denotes official action to prevent the writing or, if too late, to prevent the publication or the circulation of objectionable matter.” (15) The prevention of circulation of objectionable matter in this definition is applicable to the censorship of literature in schools as it concerns denying a particular group – junior and high school students – access to specific books.
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definition is Freedman’s reference to the limiting of access to certain ideas. More often than not, assigned literature is challenged based on the ideas and views they are perceived to express.
The final definition of censorship is provided by Helen Freshwater in her article “Towards A Redefinition of Censorship.” In her article, Freshwater examines previous contributions to the study of censorship by scholars such as Burt, Butler, Kuhn, Holoquist and Foucault. Based on the ground work established by these scholars she proposes what she considers to be an inclusive definition of
censorship. According to Freshwater, this definition is guided by the inclusive logic of ‘both/and’ rather than the censorious modality of ‘either/or’.
I propose an inclusive definition that responds to the diverse experiences of censorship, and which reflects the socio-historical specificity of instances of control, conditioning or silencing. This definition acknowledges that censorship is a process, realized through the relationships between censorious agents rather than a series of actions carried out by a discrete or isolated authority. (226)
What is useful to take from her definition is the way it presents censorship as a complex subject made up of what she refers to as “processes” and “agents.” It is this inclusion of the various processes and parties involved that makes this definition the most useful one for this particular discussion on censorship. The reason for this is that it treats censorship as a complex subject that is made up of different individuals and groups, who discuss a varied range of topics, themes and issues within society.
The censorship of books in schools is a complex matter. It involves protest from in and outside the school system as well as the motivations and the reasoning behind these protests. The term censor is used in this paper to refer to any person or group that aims to limit access to books in American (junior) high schools.
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exclude materials from the selection because of their controversial nature is to deprive students of the opportunity to gain a deeper understanding of the subject. He also makes the point that it is important to present both sides of a topic so that students engaging with the literary works at hand can form their own thoughts: “materials should express various viewpoints on a wide variety of subjects. When the subject is controversial, select material to present both sides so that pupils may draw their own conclusions” (266). Hartz’s argument implies that the selection process of literature in schools should not just focus on selecting materials which presents a one-sided view on an issue; instead, it should result in a wide selection that provides students with multiple views on any given debate. This should enable students to form opinions based on exposure to multiple arguments on a given issue. In simple terms, then, selection is the process by which a school reviews the available reading material and chooses the material that is best suited for their teaching goals and requirements; censorship, on the other hand, is the restriction or denial of access to materials already instigated. This paper does not aim to categorize every type of selection as censorship, as it is a necessary aspect of setting curriculums and reading lists. In most instances, selection is not driven by a desire to censor or restrict information, but by a number of practical factors such as time constraints, budget or availability of particular materials. Selection is considered to be censorship, when the selection process is used as a tool for excluding materials solely to avoid dealing controversial topics or having to deal with potential problems.
Agnes Stahlschmidt explains her article “A Workable Strategy for Dealing with Censorship” argues that the problem schools face is not how to squelch the efforts of censors but to ensure that “fair consideration is given to all complaints, while protecting the rights of others at the same time” (100). This view of acceptance of the views of others is a good starting point to explore the external as well as the internal aspects of censorship because it is often the case that a debate on censorship revolves around the differences in opinions of those for and against censorship.
External Censorship
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Parents are often the initiators of challenges to materials as they have a vested interest in what is taught in their children’s schools. This group can be considered to be more complex than other groups; while the other groups may have concrete standpoints on particular issues, parents are unique individuals with varying backgrounds and beliefs. The motivations of parents to challenge literature used in schools has been of interest to scholars in the field of literature. One such scholar is Suzanne Kauer, who draws on her experience as an English teacher in her article “A Battle Reconsidered: Second Thoughts on Book Censorship and Conservative Parents.” She explains that “most of the protesting parents are concerned primarily with what their own children are reading“(57), which suggests that most parents who object to the use of certain literature are doing so based on the personal values and ideals that they wish to pass onto their children.
The role that personal values play in parents’ objections to materials can be seen in an example Kauer gives in her article. She recounts an experience she had with a parent who objected to the use of a number of books in her class. The parent initially expressed concerns about The Catcher in the Rye (1951), but it turned out that she would also prefer the use of alternatives to other books on the reading list. Among these were Steinbeck’s Of Mice and Me (1937), Golding’s Lord of the Flies (1954) and Irving’s
A Prayer for Owen Many (1989). Kauer explains that the parent in question was a highly educated
person experienced in literature, who was nonetheless opposed to the use of these particular books for personal reasons. This encounter made Kauer reevaluate one of her theories on parents, which
constituted the idea that “if parents just read the books [they were objecting to] they would see some of the value and see how little the "offensive" parts matter” (58). This parent proved to the contrary, as she was – according to Kauer – an articulate and educated person who had read the books under issue and still objected to her son reading them. Her objection against Lord of the Flies was that “she wanted [her son to read] books that showed people experiencing punishment and remorse for bad behavior (her primary issue with Lord of the Flies was that even the bad boys were rescued)” (58). Kauer explains that this encounter left her asking the question of why teachers choose the books they teach to their students. She admits that she found it difficult to argue the merit of the selected material to a parent who has read the materials and thoughtfully presents counterarguments based on personal beliefs. The discussion in this case became a matter of selection and whether the selected materials equally
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Parents are not the only external group involved in challenging literature assigned in schools. According to Tunnell, many groups involved in the challenging of books do so based on religious
motives. In his article “The Double-Edged Sword: Fantasy And Censorship” he explains that these groups tend to challenge books that can be interpreted as taking on vaguely anti-Christian themes. Themes such as witchcraft or anything related to the supernatural are on the top of these groups’ lists. He explains that Baum’s The Wizard of Oz (1900) had been attacked in Tennessee for its depiction of witches in a positive manner. He also explains that even the presence of certain words in a book is enough to raise a red flag among fundamentalist groups as. Their objections include words such as “witch” that can be interpreted as anti-Christian. This points to religion and, more specifically, the defense of religious beliefs as a stimulus for religious groups to attack books which they deem harmful to their Christianity.
It is not just religious individuals that join groups in order to challenge the use of some works of literature in schools; there are many right wing activist groups and organizations that have an interest in the type of materials used in schools who attempt to ban books as well. These organizations aim to influence the selection of materials for schools by providing reviews of materials they disagree with. In her article “A Cloud of Censorship over Secondary Schools,” Berniece Seiferth discusses the groups and organizations that are actively working towards the removal of books from school libraries and
classrooms. These include organized groups such as the American Education Association, America’s Future, Inc. and the American Legislature Exchange Council. According to Seiferth, these organizations provide reviews that cite passages which they consider to be questionable. She explains that these groups attack books that they believe spread the ‘wrong’ ideas. She also points out that these
organizations frequently attack books by presenting selected passages to school officials out of context. Seiferth believes that these attempts are motivated by a desire to preserve the ‘Staus quo’. The goal of these groups is to maintain and preserve in schools what they consider to be moral values by keeping out or removing ideas – or the slightest mention of ideas – that go against their beliefs.
Among the most well known activist and censors in the United States are Mel and Norma Gabler. The Gablers have been campaigning against the use of what they consider to be objectionable literature in schools throughout the state of Texas. They have published a book titled What Are They
Teaching Our Children? (1985) in which they have compiled 24 years of experience in challenging school
literature. The Gablers’ effort have not gone unnoticed by academics. John Simmons, author of School
Censorship in the 21st Century: A Guide for Teachers and School Library Media Specialists (2001),
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wave of censorship as more “outspoken, often extreme citizens, state legislators, and state department of education bureaucrats [that] are in effect dictating both content and style of text material for our public schools” (18). The Gablers, who have campaigned to influence not just individual citizens but also legislators and education officials throughout Texas, are at the center of this category.
During their campaign to remove literature that is either inappropriate or lacking in quality from public (elementary, middle and high) schools in Texas, the Gablers focused their efforts on issues such as scientific weaknesses in evolutionary theories, phonics-based reading instruction, principles and benefits of free enterprise, original intent of the U.S. Constitution, respect for Judeo-Christian morals and
emphasis on abstinence in sex education. They also created a number of review guides for literary works that have been selected for use in high schools. Their guide consists of a number of criteria that they believe should be present in the contents of any book used in public schools. In summary, they are convinced that the books used in schools should describe a universe that rewards virtue and punishes vice, where good and evil are not moral equivalents, and where problems have solutions. Role models should demonstrate civility, sensitivity and humaneness. The book should promote positive attitudes towards the relationship between children and parents. These books should place equal stress on Europe’s literary, cultural and cultural heritages compared to other regions. The contents should demonstrate equal criticism of white and non-white cultures, as well as of Christian and non-Christian civilizations. According to the Gablers the books should provide diverse views on current controversial issues if raised. The book should not contain any sensational violence, offensive language or
illustrations, occultism, or what the Gablers’ deem to be “questionable lifestyles” (such as
homosexuality). Finally the content should not contain any stereotypes of oppressors or victims in terms of race, class, or gender. The Gablers emphasis has been mostly on materials that are considered to be anti-religion and anti-family life, which can be related to the notion of American identity, as anti-family can be understood to mean anti-American household. This description is a summary of the Gablers’ views on public education which are posted on their official website.
Some conservative organizations are also involved in the debate of what is appropriate
literature for public schools. An example would be the Eagle Forum, which campaigns for the removal of controversial literature from public schools. In an article on their website (eagleforum.org), the
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vulnerable to external influences than adults. Thirdly, the argument that a small minority group is trying to impose their beliefs on the whole community does not take into account that schools are committed to honoring the voices of all groups in the community; there is no justifiable reason to ignore the concerns of a group within the community even if they are in the minority. Fourthly, providing
alternatives to those who object to particular texts results in a diminished, isolated academic experience for students. Finally, those who defend challenged books should not forget that it is the taxpayers who funds schools and may not agree with their taxes facilitating the teaching of offensive materials.
It is not just right wing groups that attempt to censor some works of literature in schools. Liberal individuals and groups have also been reported to find certain materials used in schools objectionable. In her article “Reasons to Fight Censorship,” Bruwelheide explains that groups who claim to have liberal values have taken it upon themselves to censor materials that contain discriminatory themes.
Bruwelheide provides a few examples of materials targeted by liberal groups:
Shakespeare was deemed anti Jewish and filled with bawdy scenes and language. Mark Twain offends with his racist slurs. Materials for children should all promote nonviolence and equality of the sexes, races, and type of work. Materials by Martin Luther, St. Augustine, and Kierkegaard, to name just a few, have been attacked as sexist (416).
This is further proof that the motivation behind book banning attempts within this liberal category is the removal of themes that promote discrimination of social groups. Even though this may seem a noble reason to censor literature, researchers have disagreed with this reasoning. Bruwelheide, for instance, argues that censorship of literature that contains discriminatory themes hinders the discussion of these themes. She thinks that the best way to deal with these social issues is to openly discuss them rather than to purge literature that contains traces of them. Scholars such as Bruweldheide should also note that the discussion of controversial themes is not a simple matter. There are a number of factors that must be taken into consideration before such sensitive topics are discussed within a classroom environment.
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racist materials removed from school reading lists. In his article “Racism and "Huckleberry Finn": Censorship, Dialogue, and Change” Allen Carey-Webb touches on some of the concerns African
American parents have with the use of Huckleberry Finn in their children’s class. These concerns revolve around the racial depiction of blacks in the novel and use of the word "nigger”. Webb explains that in the “most powerful racial epithet in English the word appears 213 times and it is evident why
Huckleberry Finn legitimately concerns African American parents sending their children into racially mixed classrooms” (24). Another objection to this novel’s portrayal of African Americans is the way in which the character of Jim can be seen as an inappropriate portrayal of slaves similar to that of the black-face minstrelsy. Webb describes how some African Americans felt regarding the book being kept on the reading list after it was challenged. He explains that students in particular felt that their concerns had not been listened to. They were afraid that, by speaking out against use of the book in class, they might jeopardize their friendships with students who did not share their feelings. Some felt that the teachers were narrow-minded, shutting out the black parents and deeming their concerns illegitimate. This demonstrates another reason why a group would take offense to the use of a particular book in class; in the case of Huckleberry Finn, the book touches upon a sensitive subject such as race and slavery.
These contributions indicate that the external challenges to literature used in schools are instigated by a wide and diverse group of individuals and organizations with varying motivations. Contesters vary from activist groups such as the Gablers, who are motivated by Christian ideals, to liberals groups, who have political motivations, or parents who base their objections to the use of certain books in schools on personal beliefs and values. Yet although the motivations of censors may vary, their reasons for challenging literature are as valid to the discussion of censorship as the arguments used in the defense of books.
Internal censorship
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censorship” (264) because most staff members would rather self-censor than risk their jobs or put their schools at risk. Agnes Stahlschmidt discusses the use of selection as a way to censor materials is in her article “A Workable Strategy for Dealing with Censorship.” According to Stahlschmidt, librarians often use the selection process to avoid stocking controversial materials:
librarians are unduly influenced by the values of the community and ignore other criteria often for the sake of avoiding controversy. These decisions are often veiled by impugning the quality of a challenged work, questioning its relationship to the curriculum, or pleading lack of funds all valid arguments, except when they are used as smokescreens to avoid buying controversial materials. (99)
Freedman and Johnson also touch upon the reasoning behind self-censorship. They explain that “too often teachers choose not to use certain books for fear that these texts will create controversies leading to confrontations with parents, the members of the wider community, or school
administrators”(357). All too often, they say, teachers find themselves in the paradoxical position of believing in the importance of literature while looking for excuses to choose safer substitutions.
In her article "’There It Was, That One Sex Scene’: English Teachers on Censorship” Agee discusses how much of the censorship of literature in school falls under the category of self-censorship by teachers. She begins by explaining that when it comes to using books that contain strong language or sexual content it is not only parents and school administrators who object to the use of these books but also teachers. She explains that many teachers wish to avoid using books that might be perceived as offensive. Having conducted a survey among 375 teachers in Minnesota in the early 90’s, she provides insight into the extent of self-censorship amongst teachers and the reasoning behind it. According to Agee, “sixty percent of (. . .) teachers would not purchase books for their classrooms, even those favorably reviewed, if the books contained ‘risky’ subject matter” (61).
Scholars such as Agee, Freedman and Johnson have argued against the practice of self-censorship. Agee argues that even though self -censorship arises from good intentions it does a
disservice to students and even entire school systems. In her view, denying students’ access to particular books denies them the opportunity to develop intellectually.
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be used for required reading. He explains that although society is very flexible when it comes to books in public places or private use, books meant to be taught in schools must meet different criteria. It is for this reason that research into the censorship of literature in schools should not just focus on external censors but should also explore acts of self-censorship by teachers and librarians. The reasoning behind self-censorship in schools not only relates to the particular circumstances or beliefs of the individual who is self-censoring, but it also reflects their environment – most notably the schools and communities they work and live in.
Self-censorship in schools can be motivated out of principles, fear of repercussions, or the belief that students may not be ready or able to cope with some works of literature. These are all reasons that relate to the personal and professional circumstances of the teachers and librarians. Information on why school staffs in particular choose to self-censor can contribute to a more in-depth discussion of
censorship, presenting a whole new perspective on the discussion. Thus the arguments to self-censor should not be dismissed, but seen as insight into one of the principal actors in this discussion.
After considering all viewpoints on censorship it seems that the discussion on censorship is such a complex one that it is not possible to say whether one side (parents, teachers or government) should have control or total control over what is taught to students. This point of view stems from the belief that there is no one right answer and no one group or organization that knows exactly what is the best form of education. Thus what seems to be the best possible option is an open discussion where all sides are allowed make their case for the choices they believe are in the best interest of students. Ideally all parties involved should be willing to compromise to an extent and move towards a mutual objective which results in decisions being made based on rational argumentation that all involved will be satisfied with as it is in the best interest of the students.
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Chapter Two: Court Cases
Censorship is can be seen as matter of principle because it revolves around what different people consider to be appropriate or not. This becomes particularly evident in the better known censorship cases that have made their way to American court rooms. The fact that many of the outcomes of these cases have varied, as has the reasoning behind their rulings, shows that even the regulations surrounding censorship leave room for interpretation.
There have been cases of censorship of schools literature that have been brought to courts so that a higher authority could decide their outcomes. Among the recorded court cases concerning censorship there have been a few worth discussing in light American identity.
In his article “Parental Access to Educational Decision Making Beyond Chapter I: Affirmative Overtones of the First Amendment” Woodward explains that the first Amendment does not only protect the right of freedom of expression but also the right to receive information. This has especially been the case regarding students in public schools, whose right to received information from outside sources has been supported by the federal courts. In this sense outside sources refers to any form of information, opinions, or ideas that are presented by any source outside of school. The First Amendment is often used to support the rights of citizens, even though its wording does not direct the American government on how it should act in order to promote these freedoms, rather it prohibits it from acting in undesirable ways that would violate the constitutional freedoms of its citizens.
This original intention of the First Amendment is not very well known by the average citizen, as many people believe that their First Amendment rights guarantee them certain freedoms within society as a whole. According to Woodward the American judicial system has historically interpreted the first Amendment as a “source of restrictions on government overreaching into powers reserved to the states or liberties safe guarded to the individual, rather than as a wellspring of positive obligations imposed on government actively to promote [the expression of] freedoms”(33). Thus the First Amendment was not originally intended to promote the freedoms it lists but rather to restrict government from infringing on those freedoms. Cornel University Law School provides a digitized copy of The First Amendment:
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Barron also discusses the purpose of the First Amendment in his article “Access to the Press. A New First Amendment Right.” He explains that because there is always a possibility of governmental repression the First Amendment is intended as a way to limit some of the powers of the government. He continues that “the first amendment has served as an effective device to protect the flow of ideas from governmental censorship” (1643). The first Amendment’s original intention was to protect the people from governmental oppression, but that interpretation has gradually changed to one in which it ensures certain freedoms within the society, this is seen in the amount of censorship cases that site the first amendment either as a defense of the right to access books or as support for their arguments to remove books.
The Tinker principle
The Tinker principle originates from a court case which revolved around the censorship of free speech at a high school. This principle is relevant to the discussion of censorship within schools because it led to the Tinker standard which can be used to argue in favor of removing materials from schools. The ‘Tinker standard’ concerns the right of freedom of expression within schools. More specifically, it dictates that freedom of expression should be permitted as long as it does not interfere with the operations of the school. The Tinker test, then, is used to determine whether an act of free speech or the use of a particular material will hinder teachers’ ability to teach or students’ to learn. Regarding the use of literature in school the Tinker test can be used to argue that the inclusion of certain works may cause a disruption to the schools activities.
The principle is a result of the Tinker v. Des Moines Independent Community School District case. In 1965, students in an Iowa school planned on wearing black armbands to school in protest of the Vietnam War. School administrators took notice of this plan and, in order to avoid disturbances, they created a policy that would prohibit the wearing of these armbands. The case was brought to the U.S Supreme Court in 1969. The school administrators were unable to prove that the act of doing so would disrupt the school environment in any way; hence, the court concluded that the students were in fact allowed to express their right to freedom of speech by wearing the armbands. With this ruling the court recognized the importance of freedom of speech in schools while also making it clear that the right of freedom of speech is not absolute. As long it does not affect the teachers’ ability to teach and the students’ ability to learn, students are allowed to exercise freedom of speech.
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the censorship of the student press or other written materials within the school environment. However, in later years it had been adapted to prevent the use of potentially disruptive materials in the classroom. Fischer and Sorenson explain how this test can be used to support the censorship of literature which is considered inappropriate:
When controversies have arisen over the use of certain classroom methods or materials, especially books and magazines, courts have also been concerned about whether the use would interfere with the emotional or social development of students. In addition to obscene materials which could clearly be prohibited those materials which would be likely to lead to "libidinous conduct" or that would substantially encourage illegal behavior might successfully and constitutionally be excluded. (323)
According to Fischer and Sorensen, students’ social development is one of the major contributing factors to the suppression of forms of free speech that involve the use of potentially disruptive media. In line with the Supreme Court’s decision, schools should be able to ban any type of text that has the potential to incite inappropriate behavior in students.
In “Censorship: Where Do We Stand?” Sturm documents a number of court cases involving the censorship of literature in schools. The first court case worth mentioning is that of President's Council, District 25 v. Community School Board the United States Court of Appeals. In this case the second circuit court affirmed the ruling of a lower court ruling according to which the placement of the book These
Mean Streets (1967) on a restricted shelf was not a restriction of the students First Amendment rights.
The reasoning of the court was that the shelving of the book did not prohibit the discussion of any of the problems or ideas covered by the book. In this case, the shelving of the book only restricted access to its content and did not prohibit students to discuss its themes and topics freely. This raises the question whether just restricting access to materials can be considered as censorship in the first place if teachers and students are nonetheless free to discuss the ideas presented by the restricted materials.
Sturm provides another example of a court case regarding censorship of literature in schools as a part of the discussion in the context of freedom of speech. The Minarcini v. Strongville City School District case concerned the removal of the books Catch-22 (1961), Cat’s Cradle (1963) and God Bless
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selection and censorship: while the court ruled that the school board had not acted in arbitrary manner in its selection of books, it did rule that the removal of books from a school library is a serious burden on the freedom of the classroom discussion. The judges expressed the opinion that the availability of a book outside of the school does not minimize the burden on the classroom discussion resulting from its removal.
The First Amendment is at the core of most court cases concerning the censorship within schools. It is used both in defense of and opposed to censorship. Sturm explains that when “first Amendment values are implicated, the local officials removing the book must demonstrate some
substantial and legitimate governmental interest” (7). These governmental interests refer to the need to maintain order within society which can be related to the Tinker standard.
In his contribution Sturm also presents two cases that demonstrate school boards failing to successfully argue the presence of these governmental interests as justification for the removal of materials. The first is the case of Right to Read Defense Committee of Chelsea v. School Committee of the City of Chelsea. The school board had removed of an anthology of poems titled Male and Female based on claims that one of its poems, ‘City’, was obscene and was challenged by committee. The District Court ruled against the school board, stating that they had not shown sufficient governmental interest in their decision to remove the book on the grounds that the poem in question’s use of language can be considered as impolite but not obscene. The judges continued to state that an individual’s right to read and expose themselves to controversial language is a right that is protected under the First Amendment. The second case that had a similar ruling was that of the District Court in New Hampshire in the Salvail v. Nashua Board of Education case. In this case the local school board failed to demonstrate substantial governmental interest in its decision to withdraw MS. Magazine from the school library; the board’s decision was found to be a violation of the First Amendment. This resulted in the school board being ordered by the court to reinstate the magazine in its library.
Taking a school board or district to court over censored materials does not always result in the reinstatement of censored materials. Sturm provides an example of this in the case of Bicknell v.
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school librarians do not have an independent First Amendment right. The right to freely select materials should be in accordance with the policy established by the school board.
The American Library Association keeps tracks of a large number of court cases on the freedom to read and the First Amendment. The following are some examples of court cases where the First Amendment played a role in the courts’ decisions.
The first court case provided by the American Library Association is that of the Todd v. Rochester Community Schools case the Court of Appeals ruled that removal of Slaughterhouse-Five (1969) from the classrooms and libraries of Michigan schools was unwarranted as the students had the right to access this book if they chose to.
In the case of Loewen v. Turnipseed the District Court ruled that by refusing to approve the purchase of the textbook Mississipi: Conflict and Change because of its discussion of controversial racial subjects, the Purchasing Board denied the Authors their constitutionally guaranteed rights of freedom of speech and press.
The Case v. Unified School District was a case concerning the Kansas School Board’s removal of the novel Annie on My Mind (1982). The reason for the removal was that the School Board found the novel’s depiction of a lesbian relationship between two teenagers inappropriate for the districts libraries. The District Court in Kansas found that the School board had not only violated the students’ First Amendment rights but had also violated their own material selection and reconsideration policies.
Another case in which a school board removed a book because they found it in appropriate was the Campbell v. St. Tammany Parish School Board Case. In this case the public school district was sued by parents and students for its removal of the book Voodoo and Hoodoo (1978). Claims of the parents and students were that the removal of the book violated the students’ right to access of information. The case was taken to the Court of Appeals which remanded the case to full trial. The parties ended up settling the case before the trial began. The condition for settling was that the book be returned to the school libraries.
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In the Sund v. City of Wichita Falls, Texas, case members of a local church sought the removal the two books: Heather Has Two Mommies (1989) and Daddy’ Roommat (1991)e, because these books discussed homosexuality. The City Council agreed to restrict access to the books if at least
three-hundred residents signed a petition asking for their restriction. After this a group of citizens filled a law suit to prevent the restriction of access to these books. The District Court ruled against the City Council stating that the resolution was a viewpoint based discrimination that served no state interest. The Court also expressed that the City Council’s actions delegated governmental authority to a group of private citizens.
Island Trees v. Pico
The Island Trees v. Pico court case is another example of American Identity and freedom of speech play a role in the debate on censorship. It also provides an example of a case that receives different ruling by a number of courts. Larry L. Kraus discusses the Island Trees v. Pico court case in great length in his article “Censorship: What Island Trees v. Pico Means to Schools.” The Island Tress v. Pico case rose from the removal of nine books – Go Ask Alice (1971), A Reader for Writers, A Hero Ain't
Nothin' But a Sandwich (1973), Soul on Ice (1968), Best Short Stories by Negro Writers (1969), The Fixer
(1966), The Naked Ape (1967), Slaughterhouse-Five (1969) and Down These Mean Streets (1967) – from the high school and junior high school library by School board members after meeting with a
conservative parents organization. The school board claimed that the books in question were anti-American, anti-Christian, anti-Semitic and filthy. The removal of the books, however, was a violation of the board’s documented policies which required a formal review procedure before the questionable materials could be removed.
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the lower case court committing an error by not hearing the student’s arguments. After the Supreme Court’s decision the school board had to reinstate into the district’s libraries the nine removed books.
Kraus speculates on the intent of these Supreme Court Justices in handing out their decision. He explains that it “seems to restrict a board's rights in the library to the selection, and not the retention of books” (344). This demonstrates that there is a fine line between selection and censorship within the discussion of censorship. Kraus continues to explain that the aim of the court’s ruling was to stress the fact that selection and censorship are two different things and should be treated as such:
If the book is not selected for purchase or inclusion in the library, the Court defines this as "selection." If the time frame of this activity occurs before the book is actually in the library, no matter what the reason, the act of not selecting a particular work is not considered to be a form of censorship. If a book is removed from a library, however, and if the purpose is to curtail the dissemination of certain ideas contained in the work, this action is defined as censorship. (344)
While the Supreme Court did touch upon the difference between selection and censorship, as the example shows, the outcome of this case was in fact the result of technicalities. These technicalities include the school board’s failure to follow its own listed procedure for the removal of books and the lower court’s failure to hear the student’s arguments before making their decision on the case.
From the cases mentioned here a few conclusions on can be drawn regarding the legal aspects of censorship. To begin with, some courts do not see removing or restricting access to materials as censorship at all as long as the ideas and themes presented by these materials can be freely discussed within the classroom. This principle influenced the outcome of the President's Council, District 25 v. Community School Board the United States Court of Appeals case. Alternatively, the question whether the removal of a book places a burden on the classroom discussion became central to the outcome of the Minarcini v. Strongville City School District case, whereby the court saw the removal of the
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This again stresses that there is a distinction between selection and censorship. It also highlights that whoever is in control of the selection process has the authority to decide what should and should not be included in the curriculum.
These differences in outcomes to similar cases demonstrate that there is not a universal stand on what is considered censorship; even the different courts have different interpretations of this concept. Finally, these cases indicate that justification plays an important role in deciding whether the removal of materials is justifiable. The outcomes show that self-censors should in any case be able to demonstrate that it is in the best interest of the school or community to remove the materials under issue. This can be seen in the cases where materials had to be reinstated because their removal could not be adequately justified in the court room. Similar to instances of self-censorship amongst school staff and external censorship challenges, outcomes of court cases are often based on unique and personal circumstances of those involved in the case. The varying outcomes of the examples presented here show just how multi-facetted the issue
Chapter Three: Advice and Book Discussion
Upon examining all the information presented above, it has been decided for the advice section of this paper to focus on assisting school staff in overcoming censorship challenges. This decision was made because the beginning and end of censorship challenges often lie with school staff. After all, they are the authority which selects the books to be used in school; moreover, they will often have to defend the curriculum against challengers. The advice presented in this paper is based on the contributions of numerous scholars on censorship challenges that American schools encounter, and the solutions these scholars propose for dealing with censorship. It is important to state that this advice is intended for an American market – that is, school staff working within U.S. – as it is based on research on censorship within the United States.
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and official policies on selections and handling complaints. If staff is organized more appropriately in, for instance, a team, there will be an increase in the amount and quality of relevant information that is shared amongst staff regarding censorship issues.
Nicholas Georgiady and Louis G Romano’s article “Censorship Back on the Front Burner” touches upon the importance of internal communication within schools. It explains that a lack of communication and information on the selection of books has been as much of an internal problem for schools, where the failure to communicate with the public has been an external problem when dealing censorship challenges.
Tigner-Räsänen stresses the importance of communication among school staff when faced with censorship challenges. She explains that by working together, teachers increase their chances to successfully defend challenged materials. According to her, new as well as experienced teachers have much to gain from working together, and additionally they will benefit from improved communication. Less experienced teachers can gain from the experience of their more experienced colleagues who have faced censorship challenges in the past. More experienced teachers will benefit from the support of their colleagues as they do not have to face censorship attacks on their own.
It is not only about sharing experience: communication is important as communicating properly aids staff in being better prepared to deal with challenges to materials. All strategies and policies for dealing with censorship should be communicated to staff so that they are prepared if a censorship challenge arises. Staff should not only be able to communicate with one another regarding the official policies on challenges to materials, but they should be well versed enough to be able to discuss these with any outsiders.
It is important to analyze the school’s environment, because a sufficient understanding of their environment can help staff members predict possible objections to selected materials, as well as help them anticipate the themes or topics that may lead to objections. School staff should create an analysis of the environment and regularly update it as necessary. This can be achieved in a number of ways; staff may prepare questionnaires for parents to fill out during parent-teacher meetings, for instance. There are a number of resources which staff can turn to for guidance to create questionnaires that will suit their requirements. Once it has been decided what information is desired staff can consult both commercial and free services on the creation of effective questionnaires, which allows them to use services that fit in within any budget or time limitations.
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social groups, religious figures, social workers connected to the school, local politicians and even local journalists.
There are two benefits in creating such an analysis: firstly, it is beneficial to know what possible objections may arise, as it gives staff the opportunity to plan and create strategies around these potential objections. Secondly, staff members will be able to make increasingly informed decisions during the selection process; they can decide to avoid certain books based on whether a more agreeable substitute can be found or whether the use of this material is worth the potential objections to its inclusion in the curriculum.
Based on the contributions of scholars such as Kauer and Lowery, this paper has determined that the first step in creating an accurate analysis is that school staff become acquainted with their community, so that they are aware of its prevalent norms and values. Knowledge of the community can be incorporated into the selection process, as it can highlight potential objections to the use of
particular materials that members of the community might have.
Kauer provides an example of how an understanding of the community can help staff in the selection process. She used to teach English in a Mormon community, and as a result of the values of the community, there were certain restrictions on the materials that could be selected for the reading list. Kauer had grown up in this community so she understood its intricacies and which values parents in this community wanted to pass onto their children. The practical example she uses in het study is The
Catcher in the Rye (1951); she explains how this novel would raise objections by parents in her
community, because some of its themes go against some of their core values. She explains that premarital sex is highly disapproved of within the Mormon community and that parents actively encourage their children to abstain from premarital sex. This value is cause to conflict with this particular book as its main character, an under-aged boy, hires a prostitute (a very young one at that). Another violation of Mormon values found in this novel is the cursing; according to Kauer, Mormon parents are so sensitive to the use of any language that may be considered as foul that they do not permit their children to even see PG-13 movies. These examples demonstrate the need for an analysis of the environment when selecting books for the reading list. In this case, an analysis of the environment would have raised a red flag if this book was being considered for the reading list. It could have also helped pick a more suitable substitute that would have avoided themes considered sensitive within the community.
Staff should not just examine the community outside of the school; they should also pay
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Such an analysis should focus on the students of the school for whom literature is intended and their parents, as their cultural backgrounds may play a role in the perception of the selected materials.
A brief analysis of the different groups, races and religions that are present at the school can also help prepare staff for possible objections to selected materials, voiced by students and parents. Additionally, it will allow staff to take this information into consideration during the selection process as certain subjects and themes may elicit reactions from certain groups.
Carey-Web provides an example of how the presence of a minority group (or a group that is sensitive to certain themes) can lead to objections to the use of a particular book in an entire school. He discusses how racially sensitive themes could lead to objections by students and parents. This is
especially the case when a book such as The Adventures of Huckleberry Finn (1884) touches upon racially sensitive themes such as the use of the word ‘nigger’ or the theme of slavery, which can lead to
objections by African American students and parents.
Carey-Web explains that the objections to the use of The Adventures of Huckleberry Finn because of racial themes were picked up by the local television and newspaper reporters, which led to school staff and parents finding themselves in the middle of a very public controversy within the community. The African American students felt that they had not been listened to when they raised concerns on the use of this book, and their parents felt that the selection and retention of the book was the result of “tight-knit group of narrow-minded teachers” (23). This situation might have been avoided if teachers would have involved parents in the discussion of this book and the context in which its sensitive themes would be addressed. This approach to teaching the book could have led to a different response from members of the community had they been informed in detail how the book would be treated in class.
A useful strategy that school staff can use in the defense of selected materials is to establish policies and procedures designed to deal with censorship challenges. It is inevitable that objections will rise to the use of some of the selected materials; this is why it is important that school staff is prepared to deal with these challenges once they do arise. Once the analysis of the environment (both inside and outside of the school) is completed, staff can incorporate these findings when drafting policies and procedures to maximize the effectiveness of their defense against censorship challenges. Staff should be directed to refer any challengers to the official selection policy when they raise their objection to the use of any of the selected materials.
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removal policy can provide school staff with legal justification for their actions during a censorship case. This is also a valid strategy to be used when dealing with censorship challenges on a school or
community level.
Scholars including Mary Tigner-Rasanen, Frederic Hartz and ReLeah Cossett Lent have proposed that an effective selection policy should thoroughly outline the reasoning behind the selection of materials as will be demonstrated by the selected contributions presented here. It must also be made clear that the selected materials were chosen in order to achieve the educational objectives of the school and its district. The purpose of establishing a clearly defined selection policy is that it allows staff to refer challengers to these.
Another scholar who proposes the establishment of a clearly defined selection policy as a defense against censorship challenges is Agee. She advises school staff to create a clearly defined policy on selection that outlines the selection process and the rationale behind the selection of materials. She also stresses that the selection policy should be supported not only by an individual school, but by the entire school district. Here it becomes important to have communication with not just school staff and board members but also with school district officials. A policy will have more credibility if it is not just supported on the local school level but on a district wide level.
In his article “What Reading Teachers Can Do Before the Censors Come”, William S. Palmer explains that teachers should communicate the rationale behind their selection policy to their community. According to Palmer, teachers “should be prepared to explain why and how [they teach, because] parents and other community members have a right to know what schools and teachers are doing, and how” (310). He elaborates that many members of the community do not understand certain aspects of the curriculum, especially when it comes to areas such as reading skills and the study of literature. In addition, he states that many parents are concerned with what adolescents read, as they believe that adolescents will be greatly influenced by the literature they engage with. Palmer points out that numerous studies into the effect of literature on adolescents have disproved this notion.
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Another way in which censorship challenges can be dealt with is the establishment of a clear policy on handling objections to selected materials. Establishing such a policy will allow staff to look to this policy for guidance when dealing with complaints, as well as refer those objecting to the selected materials to this policy. This policy should outline the procedure for filing an objection in detail. The procedure for filing an objection should be clearly stated and easily referable so that staff can direct challengers to the section where they can find the information on the procedure of filing their objection.
The use of a written policy to deal with censorship challenges is not a new approach, as various scholars who are experienced in the American education system have proposed strategies that use an official policy as a defense against challenges to materials. Freedman and Johnson have also studied this; they advise school staff to establish a selection policy in order to combat censorship challenges.
According to them, many censorship challenges can be deflected or diffused by establishing an official selection policy for materials and a policy for dealing with censorship challenges.
Freedman and Johnson have also discussed the importance of an official policy for handling objections. They propose that the policy should outline a multi-staged procedure for submitting an objection. The submission process should begin with school staff and end with the school board. The first step in filing an objection should require that any objections to the selected material are submitted in written form. Freedman and Johnson suggest the use of an official complaint form in which they ask the person filing the complaint to provide an extensive amount of information (personal information, their relationship to the school and contact information) and their objections to the use of particular material. This would then be followed by a series of discussions with school staff in regards to the complaint. If after this step the individual filing the complaint still wishes to challenge the material, they are then referred to submit their objection in writing to the school board and the process starts from the beginning. According to Freedman and Johnson, this is not only the most frequently used strategy adopted by anti-censorship advocates, but also one of the most effective ones.
The final piece of advice for school staff dealing with censorship challenges is that a selection of external resources should be made available to school staff to aid in the defense of chosen works. These resources can be used as reference materials as well as provide additional resources for combating censorship. These resources may include past court cases, experiences of other teachers and administrators dealing with censorship and other resources and support systems provided by anti-censorship organizations or groups.
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support networks has been a successful strategy employed by censors aiming to get materials removed from schools, so it can be argued to be equally effective to combat censorship. As he claims,
The majority of those who succeed in having books banned are successful because they have a wide network of support ˗˗ not just local support, but also the support of national coalitions with sophisticated organizational methods. Recently, those methods have included efforts to get likeminded people elected to school boards. (547)
School staff should also adopt this strategy in their defense of challenged materials, as it increases their chances of successfully defending selected materials from censors. This strategy has a number of benefits that can contribute to a successful censorship defense. By utilizing external
resources, school staff can increase the number of resources available to staff in defense of challenged materials. They can also gain insights/knowledge into how other schools and district handled similar censorship cases.
Seeking external resources and support can contribute to awareness of the benefits of using external resources: they can be used to not just protect selected materials from censorship challenges, but also to raise awareness within the community of the importance of literature. Additionally, they also bring attention to the topic of censorship of literature. The American Library Association is an excellent example of an external resource that school staff can use. It can inform those in the school’s
environment on not just the issue of censorship, but also on the value of the study of literature. External resources can also be used to demonstrate the literary value of challenged materials and to show what they contribute to the curriculum. Potential external resources are organizations and groups such as the American Library Association, the National Coalition against Censorship and the National Council of English Teachers.
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understanding the social surroundings, they can understand which materials could potentially give rise to concerns within these communities. Staff should also be prepared to deal with any concerns or objections that arise as a result of the use of any of the selected materials. This is why it is vital that strategies for dealing with challenges and selection policies are based on relevant information from both the environmental analysis and external resources. They ought to be established accordingly. Finally, school staff members do not have to stand alone in defense of literature, as there are a number of external resources available to them to combat censorship.
Book Discussion
As a supplement to the advice provided above, this paper provides two books to illustrate censorship challenges that may arise. The first of these is a more traditional example that of the Catcher
in the Rye (1951) and the second example that of American Psycho (1991) is a more extreme one. The Catcher in the Rye has had a long history of censorship; Dawn Sova presents this history of
censorship in her book Banned Books: Literature Suppressed on Social Grounds. Sova regards the book as a favorite of censors; she explains that it has been the most frequently banned book from schools between 1966 and 1975. David Seed also discusses the novel’s history of censorship. In his review of Pamela Hunt Steinle’s article “In Cold Fear: ‘The Catcher in the Rye’, Controversies and Postwar
American Character”, Seed agrees with Sova when stating that, for more than two decades, The Catcher
in the Rye was the most censored book in schools. More specifically, between 1961 and 1982, it was the
most challenged and censored book in American high schools and libraries. As this novel has such a history of being challenged and censored, it is more than appropriate as an example for this discussion on censorship.
Helen Frangedis discusses the challenges to this book in her article “Dealing with the Controversial Elements in ‘The Catcher in the Rye’”; she explains that the “foremost allegation made against Catcher is, of course, that it teaches loose moral codes; that it glorifies attitudes and behaviors which parents condemn in their teenagers, drinking, smoking, lying, promiscuity, and more” (72). She points out that the six most controversial elements in The Catcher in the Rye are those of profanity, dishonesty, atheism, alcoholism, sexual promiscuity, and homosexuality. The above mentioned are the most widely cited reasons for challenging the use of this book, and can be seen as characteristics that may raise objections by those who find these themes inappropriate for youths.
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Interested in a little tail t’night?’[...] ‘Well how about it? Y’innarested? Five bucks a throw. Fifteen bucks the whole night.’ He looked at his wrist watch. ‘Till noon. Five bucks a throw, fifteen bucks till noon.’ ‘Okaay,’ I said. (91)
The next quotation is taken from a passage in which Holden recounts how drunk he got at a bar in New York City. He says, “Boy, I sat at that god dam bar till around one o’clock or so, getting drunk as a bastard. I could hardly see straight” (150). The profanity and relative detail with which Holden’s
drunkenness is described may give rise to criticism as well. Lastly, there is his encounter with the young prostitute in his hotel room, which can also be taken as quite objectionable; “She was a pretty spooky kid. Even with that little bitty voice she had been a big old prostitute, with a lot of makeup on her face and all, she wouldn’t have been half as spooky” (p.98). These three quotations each have at least one of the elements that Seed points out as the main reasons for parents objecting to the use of this book. Using the passages similar to the ones presented here as a basis, teachers and other school staff can predict to a certain extent the reactions that the use of this book or similar works may receive and prepare a defense as best they can.
In the 1980s, morality was used as an argument against this novel on a regular basis. Challengers of the book often argued that Holden’s actions were blasphemous. In her article “Censorship in the Schools: What’s Moral about ‘The Catcher in the Rye?’” Edwards explores and refutes some of the moral arguments used against the novel, basing her argument on philosophical writings on morality as well as how morality is represented in the Bible. She explains that philosophical theories on morality shared similar abstract principles as those found “in the New Testament which the Moral Majority and other critics claim as their moral base” (40). These principles, which Edwards utilizes to examine the novel on moral grounds, are justice, human rights and respect for individuals. Using these principles of morality as they are presented in the Bible, she argues that Holden’s actions throughout the book demonstrate his morality:
Contrary to the claims of the censors, The Catcher in the Rye is a moral book. Whether one takes as a basis for morality the teachings of Jesus, the documents of our democracy, Kohlberg's levels of moral reasoning, or some other source, Holden Caulfield emerges as a confused but moral person. (42)
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identity, as this scholar used a religious angle to demonstrate that Holden does indeed possess some Christian moral values.
Studying Edwards’s example, it can be suggested that challenges to books may be used as opportunities to argue for the importance of teaching literature and its interpretation. She
demonstrates that, using the interpretation of Holden’s actions throughout the novel, it can be argued that he does exhibit the traits and qualities that challengers of this novel claim he lacks. Teachers can use such examples to argue the complexity of literature and how the interpretation of it can vary from one reader to another.
In these instances, teachers should not shy away from the controversial themes and topics, but use these as the starting point of their discussions of the literature in question with students as well as with parents. It is very important to explain in detail the context of controversial passages and elaborate on how they will be discussed. This approach can help avoid disputes when explaining the purpose of these themes and topics within the book, and elucidate how they contribute to potential interpretations of the book.
In the case of this book, teachers should explain not only the context of its criticized passages, but also how these contribute to the narrative. The aim here is to discuss why certain themes or topics are in the book, and to provide an explanation on their purpose and how these will be addressed in class. The message that should be conveyed is that these topics and themes were not added by the author for the sake of including them, but for them to serve a purpose. For example, Holden’s cursing and the sexual reference can be argued to be in the book to provide a more realistic depiction of a teenage boy, or to make his character more relatable by younger readers.
In the case of Bret Easton Ellis’s American Psycho, it is a more extreme example as it contains graphic descriptions of acts of violence as well as sexually explicit scenes which would most likely raise objections if the novel were placed on any school’s reading list. As the objections brought on by these two themes in the novel are simple to grasp, this discussion would benefit from an examination of its treatment of women. School staff can benefit from an analysis of a more complex social issue as these might be used as an argument against the use of a selected book.
