During the 1970s, courts repeatedly overruled acts of administrative censorship of high school publications, even when the publication in question included "earthy" language or attacks on school officials. The trend toward expanding students' First Amendment rights began in 1969 with the "tinker" ruling, which reaffirmed the right of three students to wear black armbands to class as a protest against the Vietnam war. At the high school level, 12 court decisions overturned censorship or discipline of student journalists by administrators in the 1970s. But a trend toward conservatism is emerging as language and subject matter that would have been tolerated by administrators only a few years ago are being censored in the 1980s. Beginning in 1977 with a ruling in favor of a school administration's act of prior restraint, in refusing to allow students to distribute a questionnaire concerning sexual attitudes on the grounds that the censored questionnaire "might" upset students, students lost a series of important court decisions that surely would have been won a few years earlier. School officials who censor student publications still risk a reversal in court, but more and more judges may be willing to overlook the "tinker" ruling and defer to school officials' predictions of disruption. (HTH)