Teachers' Social Media Use and Its Legal Implications

The William & Mary Educational The William & Mary Educational

Review Review

Volume 8 Issue 1 Article 4

2023

Teachers’ Social Media Use and Its Legal Implications Teachers’ Social Media Use and Its Legal Implications

Martha Crockett

William & Mary

Lavare Henry

William and Mary

Stephanie McGuire

William and Mary

Ayse Gurdal

William and Mary

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and Its Legal Implications,"

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As of 2022, 58.4% of the population uses social media for a daily average of 2 hours and

27 minutes (Chaﬀ ey, 2022). In other words, 4.62 billion people worldwide are getting

online to connect with others, digest news, and seek entertainment. (Pew Research Cen-

ter, 2021). Having discovered the personal and professional beneﬁ ts of social media, ed-

ucators, and more speciﬁ cally teachers, account for a portion of these subscribers. While

social networking sites have the potential to contribute positively to K-12 communities,

such as deepening relationships between teachers and students or increasing accessibil-

ity to professional development, they also present a variety of ethical dilemmas of which

all school employees should be wary. These precarious situations can include teacher

engagement in illegal activity, behaviors that reﬂ ect poor professional judgments, and

inappropriate contact with students (Warnick et al., 2016). School leaders are now ex-

ploring how to create guidelines around teacher social media use that honor employees’

First Amendment rights to free speech, while also maintaining the collective responsi-

bility to create safe and productive learning environments. Therefore, the purpose of

this paper is to review relevant landmark and recent court cases in order to inform the

Abstract

As society becomes increasingly dependent on technology, school leaders must navigate

the evolution of websites, resources, and platforms, including social media, as part of

their responsibility to facilitate a safe and productive learning environment for students.

This article reviews both constitutional and case law as a means of informing educational

leaders of their rights and duties, as well as providing a foundation upon which eﬀ ective

K-12 social media policies and practices for educators can be built. Speciﬁ cally, we oﬀ er

an analysis of landmark cases involving the First Amendment and free speech, the delica-

cy around teachers’ roles as both public employees and private citizens, and recent court

cases involving social media use. Additionally, we propose guidelines around social media

use, compiled from both practitioners in the ﬁ eld and relevant literature.

Teachers’ Social Media Use

and Its Legal Implications

Martha Crockett

, Lavare Henry

Stephanie McGuire

, and Ayse Gurdal

Keywords

social media, school leadership, law

William & Mary

The William & Mary Educational Review

2022/2023 Vol. 8, No. 1

development of eﬀ ective K-12 teacher social media policies and practices.

Teachers’ Social Media Use

Social networks have changed contemporary life, in terms of how “individuals play,

socialize, worship, and work” and oﬀ er “a signiﬁ cant way to express individuality and to

build and aﬃ rm connection with others” (Warnick, et al., p. 772). These online sites, such

as Twitter, Facebook, Pinterest, and Instagram, oﬀ er endless opportunities for teachers

to connect with others for both personal and professional purposes. As private citizens,

teachers can share updates, in a variety of formats, with friends and family. As public

employees, they are able to network and learn alongside other professionals, parents, and

students. However, social media also contests the traditional construct of teaching, stu-

dent learning theory research, and even the organization and structure of schools (Bar-

tow, 2014). While using social media can appear novel and exciting, it is important for

teachers to critically consider both the advantages and drawbacks associated with online

engagement.

Personal Use

Teachers are citizens who have families and friends, as well as hobbies and interests

outside of work, and share the basic need for human connection (Stiles, 2021). Some of

the top reasons the general population uses social media include staying up to date with

news, ﬁ nding entertaining content or researching products, sharing photos or opinions,

and staying in touch with others (Kemp, 2021). The Pew Research Center reports that

seven-in-ten Americans use social media, a statistic “that has remained relatively stable

over the past ﬁ ve years” (Auxier & Anderson, 2021). So, it is not surprising that 71%

of instructors use Facebook for personal reasons on a daily basis, followed by Google +

(33%), Pinterest (32%), Instagram (27%), and Twitter (18 %) (Ascione, 2016).

Professional Use

Educators are taking advantage of social media in a variety of ways, ranging from

distributing information and creating community to revising pedagogy and acquiring ma-

terials. For example, Twitter is an eﬀ ective tool with which schools can disseminate infor-

mation, in 280 characters or less, to parents and students. Because Facebook is one of the

most extensively utilized social media platforms and contains features including “bulletin

boards, instant messaging, e-mail, and the ability to post videos and pictures” (Warnick,

et al., 2016, p. 777), it is an important site for community engagement. Many youth use

Instagram themselves, which makes this popular platform, for photo and video posts, a

crucial space for facilitating relationships and belonging (MMS, 2022).

In terms of professional development, emerging educational trends, engaging discus-

sions, and new tools and pedagogy can all be found on Twitter. Additionally, educators

use this site to explore vendors, goods, and programs they might want to implement in

The William & Mary Educational Review2

their classrooms using hashtags and searches (MMS, 2022). Facebook oﬀ ers educators a

space to interact with colleagues, share materials, and follow relevant ﬁ rms and organi-

zations (MMS, 2022). Schools also use Pinterest to publish their own content, such as re-

sources for parents to assist with homework and student needs (Ascione, 2016). YouTube

not only hosts thousands of videos, outlining classroom activities, product demos, and

training, but also enables teachers to create their own channels, containing class materi-

als and resources for students (Ascione, 2016).

First Amendment and Four Landmark Cases

To date, there have been no Supreme Court rulings that have explicitly responded to

teachers and students on social media. Therefore, administrators must call upon more

general legal precedents when responding to ethical dilemmas and creating new poli-

cies. Three cases in particular, Pickering v. Board of Education (1968), Perry v. Sinder-

mann (1972), and Garcetti v. Ceballos (2006), have revealed some of the nuances related

to the free speech of public employees. Even though only one of these cases involves a

K-12 teacher and none of them is related to online communication, all of the outcomes

contribute to the foundation upon which decisions involving social media regulation are

made. An additional case, Tinker v. Des Moines (1969), established an important stan-

dard around protecting the safety and eﬃ ciency of K-12 student learning environments.

First, the Pickering v. Board of Education (1968) case has helped clarify free speech

rights of public employees, in regards to the connection of the speech to the employee’s

oﬃ cial duties and to public concern. The U.S. Supreme Court ruled that public school

teacher Marvin Pickering’s First Amendment rights had been violated when he was ﬁ red

for penning an editorial criticizing his employer in a local newspaper. The outcome of

this case set a precedent for the broad nature of teachers’ rights to expression, as long as

they neither disrupt instructional interests nor undermine authority in a way that would

negatively impact working relationships in school districts. Several years later, the notion

of First Amendment Rights of public employees was reﬁ ned in the Perry v. Sindermann

(1972) case. Here, Sindermann, a professor at a junior college in Texas, was dismissed on

account of his “insubordination,” after having publicly criticized the school’s Board of Re-

gents. The Supreme Court determined that his First and Fourteenth Amendment Rights

were violated, as his right to free speech existed independent of his non-tenure status,

and he had not been oﬀ ered due process before his termination.

The Garcetti v. Ceballos (2006) case further reﬁ ned the relationship between public

employees’ oﬃ cial duties and their rights to free speech. This incident involved Garcetti,

former Los Angeles District Attorney, and Ceballos, one of his employees who criticized

the legitimacy of a warrant and aﬃ davit, before facing professional consequences. The

Supreme Court found that the speech in question was made in Ceballos’s oﬃ cial capacity

and therefore not protected by the First Amendment. The diﬀ erence between Pickering

and Ceballos is that the former was speaking as a private citizen about a public concern,

Crockett et al.

and the latter was performing public duties. This important distinction in the context of

free speech contributes to the determination of whether or not First Amendment rights

are guaranteed.

Finally, the Tinker v. Des Moines (1969) case resulted in formation of the “substantial

disruption test,” which is used to determine the extent to which the school’s interest to

maintain a favorable learning environment can limit students’ access to their First Amend-

ment Rights. In this situation, students who wore black armbands protesting American

involvement in the Vietnam War were suspended from school. Once the case reached the

U.S. Supreme Court, there was a majority rule that neither students nor teachers “shed

their constitutional rights to freedom of speech or expression at the schoolhouse gate” (as

cited in Schimmel et al., 2015, p.162). Because the armbands did not interrupt student

productivity, the schools did not have the right to suspend the students. School leaders

today can use this same evaluation technique, when monitoring social media use.

In Search of Balance

At the heart of the landmark cases described above is the need to balance teachers’

rights as private citizens with their duties as public employees responsible for managing

schools safely and eﬃ ciently. This is a challenging task for both K-12 administrators and

court oﬃ cials, as there is much unchartered territory in this unfolding online landscape.

Freedom of speech is a right guaranteed in the U.S. Constitution, as outlined in the First

and Fourteenth Amendments. The Supreme Court, which serves as the primary guardian

of this foundational document, is very protective of this right and will only curtail it if the

government provides a compelling reason to do so (Ryan, 1988; Schimmel et al., 2015).

Through these four landmark cases, the Supreme Court has established some clarity for

the lower courts, school leaders, teachers, and the public at large on how to balance teach-

ers’ rights and responsibilities. In situations where teachers’ private lives have spilled into

the public domain, the courts have largely maintained teachers’ freedom of expression

over the schools’ need for eﬃ ciency. Rulings in favor of the schools have only been made

in situations where the schools have been able to prove teachers’ speech has negatively

impacted their ability to operate (Schroeder, 2013).

Normally, schools do not regulate oﬀ -campus teacher activity; teachers are free to

post and share what they want on their social media accounts. However, once a “nexus, or

causal connection with the school environment [is discovered], [the teacher] is subject to

regulation by the school” (Bathon & Brady, 2010, p. 216). For example, one teacher who

posted on Facebook calling her students “chitlins in the ghetto” was eventually dismissed

for her comments (Bathon & Brady, 2010, p. 214). This situation, alongside others, has

spurred discussions about the lack of geographical and time boundaries around com-

munication among school employees, parents, and students. Additionally, teachers have

found that despite the availability of privacy settings, social media sites do not always

guarantee protection against hackers or loopholes (Estrada, 2010). Thus, as schools work

The William & Mary Educational Review

to establish teacher guidelines, amidst ﬁ rm legal clarity, teachers must consider potential

risks associated with enjoying their free speech rights online.

How the Courts Decide

The courts have set out a framework to guide determinations, related to the balance

between teacher rights and responsibilities. The ﬁ rst step involves an examination of

whether school leaders’ actions against a teacher are based solely on the teacher’s pro-

tected speech or involve other actions or behavior. In the case of Mt. Healthy City Board

of Education v. Doyle (1976), Doyle, a public school teacher, was ﬁ red and subsequently

sued the school district. Even though he had shared internal information with a local ra-

dio station, the court ruled that the many other factors contributing to Doyle’s dismissal

(making obscene gestures at students, cursing students, and violently confronting an-

other teacher) were enough by themselves to warrant his dismissal (Hudson, 2002). His

First Amendment rights related to the radio were protected; however, the other issues

were enough grounds for his dismissal. In other words, an employee must demonstrate

that they suﬀ ered an adverse employment action as a result of making their protected

expression (Younger, 2016).

After exploring whether the action taken against the teacher in question is based solely

or primarily on his or her expression, the courts consider the context, or rather the public

vs. private nature of the speech. If a comment is made as part of an individual’s public

responsibilities, it is not protected as the comment was not made as a private citizen. The

First Amendment does not protect expressions that occur outside job boundaries, are

based on self-interest, involve personal complaints, or injure relationships in the work-

place. In the case of Connick v. Myers (1983), the court upheld Myers’s dismissal from her

assistant district attorney position in Louisiana after she had distributed a questionnaire

expressing personal concerns about her transfer to colleagues. Because Myers’s actions

disrupted the workplace and created a burden in the workplace for her superior, Connick,

the judges decided that her free speech rights had not been violated. This case established

that a matter of public concern can transform into a matter of private concern, when mo-

tivated by malice or personal grievance (Schimmel et al., 2015). The Garcetti v. Ceballos

(2006) case provides another example of the court ﬁ nding the actions taken against the

respondent permissible, given that he had acted in his oﬃ cial capacity but out of the

scope of his authority (Younger, 2016).

Next, the courts examine if the expression is made in an individual’s private capacity

and if the expression is a matter of public concern. If an individual is speaking in a private

capacity, the Pickering Balance test can be used to evaluate whether that person had inside

knowledge from his or her job. If the information used emerges from the work position,

the speech is not protected in that individual’s capacity as a private citizen (Ryan, 1988;

Younger, 2016). In the case of Pickering v. Board of Education (1968), the court made

clear that teachers speaking on matters of public concern (social, political, legitimate

Crockett et al.

news, or issues of interest or concern to the general public) are guaranteed their Consti-

tutional rights to do so. It also required that the state prove that the need to maintain an

eﬃ cient functioning work environment outweighs teachers’ free speech (Schimmel et al.,

2015). To determine if the need for school eﬃ ciency outweighs the employee’s right to

free speech, the court applies the substantial disruption test, established in the Tinker v.

Des Moines School District (1969) case, as well as the true threat test. Substantial disrup-

tion refers to the likelihood of the speech to disrupt the operations of the school, create a

hostile working environment, create issues of safety, and diminish oﬃ ce loyalty and trust

(Younger, 2016). The true threat test is also used to evaluate the protection of free speech.

A threat, or an expression of intent to do or cause harm made with the intent to produce

fear and intimidation to the target (Schimmel et al., 2015), is considered a true threat if a

reasonable person would interpret the threat as a serious intent to cause harm (Hudson,

2002). In the case of Givhan v. Western Line Consolidated School District (1979), the

court ruled that the content, time, place, and manner of the speech must be taken into

consideration when evaluating a threat.

Finally, if the expression is not a matter of public concern, then the courts apply the

geography test. In Hazelwood School District v. Kuhlmeier (1988), the court upheld that

schools have the right to exercise editorial rights over a school-sponsored activity, as long

as it is reasonable (Schimmel et al., 2015). This same principle applies to expression on

school grounds, while oﬀ campus expression is generally protected by the Constitution.

Although teachers can exercise their free speech rights more liberally in the public do-

main than in classrooms, they are still subject to the substantial disruption test. If an

issue arises oﬀ campus, the school leaders must prove there is a nexus, or connection

between the teacher and his or her ability to work eﬀ ectively (a substantial disruption

to school’s operations) (Schimmel et al., 2015). Therefore, time, place, manner, context,

and consequences are all important factors in the determination of whether a school’s

interest outweighs a teacher’s right to freedom of expression. The principles established

in these landmark cases have all played roles in recent court cases related to teachers’ use

in social media. We will brieﬂ y discuss some of the more recent cases in the next section.

Recent Cases

Alongside the rise in teacher social media use, has come an increase in the number of

related legal cases, which have created more direction from which school and court oﬃ -

cials can make future decisions. In these cases, taking place in the early-to-mid 2000s, the

courts have applied the substantial disruption test, considered if the speech was protected

as a matter of public concern, and determined if the speech interfered with the teachers’

ability to do their jobs. The associated outcomes have set the precedent that teachers

must separate their professional roles from their personal activities, student teachers are

evaluated as employees rather than as students, and schools must be able to maintain

eﬃ cient operations.

The William & Mary Educational Review

Crockett et al.

First, in Spanierman v. Hughes (2008), Spanierman, an English teacher, who had

created multiple MySpace accounts with pictures of naked men and comments about stu-

dents’ personal lives, believed his First and Fourteenth Amendment rights were violated

when his contract was not renewed (Dennis, 2011). However, the court found Spanier-

man’s online conduct was not appropriate for a teacher, that most of his online comments

were not protected speech, and that his behavior did cause a disruption for the school

(Dennis, 2011). This teacher’s free speech was not protected because the substantial dis-

ruption test determined he had disturbed the learning environment, even though the in-

teractions had taken place outside of school (a nexus between personal life and school

disruption was established).

In the same year, the courts set an important precedent not just for teachers, but also

for student teachers. In Snyder v. Millersville University (2008), Snyder, a student teach-

er at Millersville University working in a high school English class, uploaded posts on her

MySpace page that contained grammatical errors and a picture in which she was wearing

a pirate hat, holding a cup that says “drunken pirate” (Russo, 2009, p.39). Once another

teacher found the post and shared it with the superintendent, Snyder was not allowed to

complete her student teaching assignment, was marked down for professionalism, and

ultimately did not pass student teaching or receive her degree in education (Russo, 2009).

In response to her suing the university, the court found that in her student teacher role,

Snyder was more of an employee than a student, so her speech was not protected, since it

did not “involve a matter of public concern.” (Russo, 2009, p.40) Therefore, the univer-

sity was justiﬁ ed in withholding a degree in education and a recommendation for teacher

certiﬁ cation from her (Russo, 2009). In this case, the courts applied the Pickering test,

determining that the employee’s speech about was not a matter of public concern, and set

the precedent that the courts view student teachers as employees, rather than as students.

Although these two cases represent instances in which the courts favored the schools

over the teachers, Murmer v. Chesterﬁ eld County School Board United States District

Court, Richmond (2008) oﬀ ers an example of a teacher prevailing. In his free time, Mur-

mer, a high school art teacher, made paintings using his buttocks (ACLU Virginia, 2022).

His colleagues discovered a recording of his TV appearance on YouTube. Even though

he was wearing a mask, head towel, bathrobe, and thong swimsuit at his art demonstra-

tion in the video, he was ﬁ red from his job (ACLU Virginia, 2022). With the help of the

ACLU of Virginia, he ﬁ led a lawsuit claiming his First Amendment rights were violated

(ACLU Virginia, 2022) and ultimately won. The court sided in his favor, with a deter-

mination, using the geography test, that his art demonstration did not adversely impact

his eﬀ ectiveness as a teacher (there was no nexus between his personal and professional

lives). Murmur was awarded two years’ salary for his suﬀ erings in the amount of $65,000

(ACLU Virginia, 2022; ACLU, 2008) and contributed to the precedent that a teacher can

maintain private citizenship, so long as their personal acts do not impact their teaching

ability and classroom environment.

The William & Mary Educational Review

The following year, the courts heard another case evaluating the relationship between

teachers’ social media presence and their ability to carry out professional duties. In Rich-

erson v. Beckon (2009), Richerson, a curriculum specialist and instructional coach, be-

gan posting about the teachers she was coaching, other colleagues, union representatives,

and employers to the degree that they could be identiﬁ ed by her descriptions (Richerson

v. Beckon, 2009). These negative and personal posts diminished trust with the employees

she mentored and disrupted her coaching abilities. When Beckon, the Director of HR,

moved her back to the classroom as a teacher, Richerson argued her First Amendment

rights were infringed. However, the court ruled in favor of the school district, citing her

social media use as interference to her work. Again, the courts used ability to perform

eﬀ ectively as a barometer for judgment when contemplating an individual’s First Amend-

ment rights.

In Payne v. Barrow (2009), Payne, who taught high school English, was asked to

resign, after a parent had reported her social media posts in which she was “holding a

beer in an Irish pub” and had “used the word bitch” (O’Connor & Schmidt, 2015, p.7).

Although her account was set to private, Payne did honor the principal’s request for her

to leave, based on her naivety and lack of understanding about her rights. Her resignation

without question underlines the importance of teachers taking caution to know how they

can respond in these situations. Later, the court ruled in favor of the school district be-

cause she was non-tenured (O’Connor & Schmidt, 2015).

A few years later, another teacher used harsh language, which led to an even larg-

er disruption than one parent phone call. In Jennifer O’Brien v. State Operated School

District of the City of Paterson NJ Superior Court, Appellate Division (2013), O’Brien,

a ﬁ rst grade teacher, posted “I’m not a teacher I’m a warden for future criminals! They

had a scared straight program in school why couldn’t [I] bring [ﬁ rst] graders?” Her action

led to one parent request to remove their child from the school, at least 12 more angry

parent telephone calls, and a protest of an additional 20-25 outside of the school. Rather

than honor O’Brien’s belief that this was a public concern, the court found in favor of the

school district and removed her from her tenured position because the ability to maintain

an eﬃ cient operation of the school outweighed concerns about the students’ behaviors.

In this case, the substantial disruption test was applied, and the school district prevailed.

Another instance concerning job eﬀ ectiveness occurred in Shepherd v. McGee (2013).

Shepherd, a child protective services worker, posted negative comments about individ-

uals who were receiving assistance (Holland & Knight LLP, n.d.). The court found her

comments to negatively impact her eﬀ ectiveness as a CPS worker and her ability to be a

witness in court (Holland & Knight LLP, n.d.). Because her comments met the require-

ments of the substantial disruption test, the case was settled in summary judgment in

favor of McGee, the manager of Human Resources, not Shepherd, the child protective

services worker.

Figure 1

Framework for Assessing Social Media Posts Based Our Synthesis of Court Cases

The courts cycled back to the use of the Pickering balancing test in Munroe v. Central

Bucks School District (2014). In this case, Munroe was a high school English teacher

who posted negative comments about her students on her online blog. She posted a list

of comments that she thought should be part of the automatic report card choices con-

taining oﬀ ensive language and demeaning comments, which resulted in her termination.

Although she argued this infringed on her First Amendment rights, the court found in

favor of the school district, thanks to the Pickering balancing test, as Munroe’s blog posts

were disruptive enough to upset the learning environment.

Implications

Providing a safe learning environment for all students is one of the top priorities of

K-12 educators. With the rapid evolution of technology, school oﬃ cials are faced with the

challenge of not only monitoring teacher communication, but also evaluating its eﬀ ects

on student learning (Bathon & Brady, 2010). As teachers explore the boundaries of social

media as a means of building rapport with students, sharing information with families,

and enhancing their pedagogies, they must carefully weigh their rights as private citi-

zens against their duties as public oﬃ cials. Teachers should take into consideration past

court cases, existing school and district policies, and research-based recommendations

Crockett et al.

The William & Mary Educational Review

on social media use to ensure both their Internet safety and their job security. It is the

responsibility of administrators to “assist teachers in navigating these complex waters

while still protecting the integrity and safety of the school” (Bathon & Brady, 2010, p.

223). Although a handful of cases have made it to the courtroom, thousands of others

have been resolved within schools; therefore, the wisdom of school oﬃ cials should not be

discredited (Bathon & Brandy, 2010).

Recommendations

While school districts cannot completely forbid teachers from using social media, they

can take steps to create and implement guidelines around appropriate behaviors. Even

without U.S. Supreme Court rulings on cases on this speciﬁ c topic, K-12 leaders can call

upon landmark and lower court rulings as a compass for determining when to defend

employees’ speech and when to protect the school community. Figure 1 below provides

an original guide to help leaders in the decision-making process should they have a so-

cial media issue to address. First, school leaders should provide clear social media policy

guidelines and communicate to staﬀ at all levels. In order to increase teacher awareness,

it would be helpful to involve them in the creation of the policy and positive social me-

dia use advocacy groups at schools. School leaders should also oﬀ er trainings, perhaps

during teacher orientation, on teachers’ rights as citizens and responsibilities as employ-

ees (Russo, 2009). School districts can consider installing ﬁ rewalls and limiting access to

these sites from district-owned systems, and requiring employees to sign acceptable use

policies (Russo, 2009).

More teacher-speciﬁ c recommendations from the literature include not posting about

students or venting on the Internet, being familiar with the school district’s social media

policy and state laws, and turning on social media privacy settings, even though privacy is

not always guaranteed (O’Connor & Schmidt, 2015). Additionally, it is important to com-

municate professional expectations with student teachers. Practitioners and school leaders

discussed strategies and valuable practices in advising teachers on how to use social media

appropriately and how not to use social media which might lead to the detriment of a career.

A summary of these suggestions can be found in Appendix A. More research exploring the

impact of social media on teaching strategies, community relationships, learning outcomes,

etc. is needed to inform the development of policies around technology use in K-12 schools.

Conclusion

The evolution of technology, and more speciﬁ cally social media, has certainly present-

ed a variety of new encounters through which all K-12 stakeholders have begun to navi-

gate. Although there are beneﬁ ts of online interactions to student learning, there are also

various instances involving the misuse of technology that have resulted in the disruption

of learning environments. The most severe cases have resulted in teacher discipline, or

even disputes in the courts. As educators forge ahead into the 21st century, they have legal

precedent, formal research, and lived experience with which they can continue to assess

and determine the role of social media in K-12 schools.

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Appendix A

Guidelines From Field Practitioners on Navigating Social Media Use as an Educator

Do:

• Utilize privacy settings

• Maintain separation between your private and professional accounts

• Review old posts on your accounts

• Recognize that as an educator, you are put on a moral pedestal

• Separate yourself from your position and the division in your post and on your

accounts

Do Not:

• Post negative comments about your job

• Use your professional accounts for personal reasons

• Vent on social media

• Post naked photographs

• Post about alcohol, drugs, or parties

• Connect with students and parents on personal accounts

• Interact with students on social media

And when posting:

• Consider the purpose of your actions

• Assume that everything is public

• Assume the superintendent will see all the pictures you post

The William & Mary Educational Review

Guidelines are from a class. Personal communication, March 6, 2022