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40 Ariz. St. L.J. 257 (2008)
Case for Strengthening School District Jurisdiction to Punish Off-campus Incidents of Cyberbullying, A

handle is hein.journals/arzjl40 and id is 265 raw text is: A CASE FOR STRENGTHENING SCHOOL
Todd D. Erbt
Not long ago, society treated incidents of hazing, harassment, and
bullying as part of the growing-up process. Today, however, we live in the
shadow of sensational events that have changed the way our nation treats
threats and bullying in our public school system. Our nation is engulfed by
the epidemic of violence in public schools.' Just as the September l1th
attacks shifted the nation's paradigm concerning issues of national security,
the 1999 shootings at Columbine High School changed the way school
administrators handle threats from students against faculty or other students
on campus.2 School administrators are now faced with further dilemmas,
however, because on-campus bullying is now amplified by off-campus
bullying on the Internet-a phenomenon called cyberbullying.'3
Cyberbullying occurs when students use electronic means, including the
use of Internet web sites, chat rooms, instant messaging, text and picture
messaging on phones, and blogs, to bully peers.4 The only real difference
t    Note and Comment Editor, Arizona State Law Journal. J.D. Candidate, Sandra Day
O'Connor College of Law at Arizona State University, 2008; B.A. Political Science, Brigham
Young University, 2005. I would like to thank Professor Tamara Herrera: an exceptional teacher
and mentor. I would also like to thank Daneille Erb for her constant encouragement and Jack
Erb for providing insights into current school law issues. Finally, I owe a special thanks to
Kristin Erb for her untiring love and support.
1.  See In re Douglas D., 626 N.W.2d 725, 749-50 (Wis. 2001) (Prosser, J., dissenting)
(Over the past eight years, American education has endured an unprecedented outbreak of
shooting incidents and other violence at schools across the United States. Parents, teachers,
school administrators, and students have become hauntingly familiar with such names as
Grayson, Kentucky (2 deaths, 1993); Lynnville, Tennessee (2 deaths, 1995); Blackville, South
Carolina (3 deaths, 1995); Redlands, California (1 death, 1995); Moses Lake, Washington (3
deaths, 1996); Bethel, Alaska (2 deaths, 1997); Pearl, Mississippi (2 deaths, 1997); West
Paducah, Kentucky (3 deaths, 1997); Jonesboro, Arkansas (5 deaths, 1998); Edinboro,
Pennsylvania (1 death, 1998); Fayetteville, Tennessee (1 death, 1998); and Springfield, Oregon
(2 deaths, 1998), all of which occurred before the incident in this case and all of which preceded
the 15 deaths at Columbine High School in Littleton, Colorado in 1999. A number of these
shooting deaths were perpetrated by boys between 12 and 14 years of age.).
2.   See Columbine High School Massacre, http://en.wikipedia.org/wiki/ColumbineHigh
School-massacre (last visited Feb. 26, 2008).
3.   Renee L. Servance, Comment, Cyberbullying, Cyber-Harassment, and the Conflict
Between Schools and the First Amendment, 2003 Wis. L. REv. 1213, 1218 (2003).
4.  Id.

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