nstitution. The second involves "nonacquisition" in which the plaintiffs contend that the decision not to acquire or use specific material is a form of censorship. A third situation involves decisions in the classroom regarding the assignment of controversial materials related to coursework. The final challenge involves the modification of a curricula in a manner that might suggest censorship (Reichman, 1993, p. 90).
In ruling on school censorship cases, U.S. Supreme Court justices have failed to adopt a uniform approach. Given the complexity of the censorship issue, this is not surprising. Two approaches have emerged in rulings on cases since the 1970s--both based on the justices' view of the nature and function of schools in society. The faction headed by Chief Justice Burger emphasizes the role of education in indoctrinating community values and accepted truths: "The function of teacher, school, and educational materials is to convey these truths, rather than create new wisdom" (North, 1992, p. 180). The opposing faction on
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