Case: 12-60264 Document: 00513162565 Page: 15 Date Filed: 08/20/2015 No. 12-60264 14. In holding the students’ speech protected under the First Amendment, the Court, focusing primarily on the effect of that speech on the school community, held: A student “may express his opinions . . . if he does so without materially and substantially interfer[ing] with the requirements of appropriate discipline in the operation of the school and without colliding with the rights of others”. Id. at 513 (alteration in original) (emphasis added) (internal quotation marks omitted). Put another way, “conduct by the student, in class or out of it, which for any reason . . . materially disrupts classwork or involves substantial disorder or invasion of the rights of others is, of course, not immunized . . . ”. Id. (emphasis added). Approximately three years after Tinker, our court held this standard can be satisfied either by showing a disruption has occurred, or by showing “demonstrable factors that would give rise to any reasonable forecast by the school administration of ‘substantial and material’ disruption”. Shanley v. Ne. Indep. Sch. Dist., Bexar Cnty., Tex., 462 F.2d 960, 974 (5th Cir. 1972) (emphasis added) (holding school’s suspension of students for their offcampus distribution of “underground” newspaper violated Tinker). Since Tinker, the Court has revisited student speech on several occasions, each time carving out narrow exceptions to the general Tinker standard based on certain characteristics, or content, of the speech. See, e.g., Morse, 551 U.S. at 425 (Alito, J, concurring) (grave and unique threats to the physical safety of students, in particular, speech advocating illegal drug use); Hazelwood Sch. Dist. v. Kuhlmeier, 484 U.S. 260, 273 (1988) (school-sponsored speech); Fraser, 478 U.S. at 685 (lewd, vulgar, or indecent speech); see also Morgan v. Swanson, 659 F.3d 359, 374 (5th Cir. 2011) (en banc) (describing the Court’s holdings as “expand[ing] the kinds of speech schools can regulate . . . . to several broad categories of student speech” (internal quotation marks omitted)). In Fraser, the Court held the school board acted within its authority 15