Case: 12-60264 Document: 00513162565 Page: 19 Date Filed: 08/20/2015 No. 12-60264 decided, the Internet, cellphones, smartphones, and digital social media did not exist. The advent of these technologies and their sweeping adoption by students present new and evolving challenges for school administrators, confounding previously delineated boundaries of permissible regulations. See, e.g., Wynar v. Douglas Cnty. Sch. Dist., 728 F.3d 1062, 1064 (9th Cir. 2013) (“With the advent of the Internet and in the wake of school shootings at Columbine, Santee, Newtown and many others, school administrators face the daunting task of evaluating potential threats of violence and keeping their students safe without impinging on their constitutional rights.”). Students now have the ability to disseminate instantaneously and communicate widely from any location via the Internet. These communications, which may reference events occurring, or to occur, at school, or be about members of the school community, can likewise be accessed anywhere, by anyone, at any time. Although, under other circumstances, such communications might be protected speech under the First Amendment, off-campus threats, harassment, and intimidation directed at teachers create a tension between a student’s freespeech rights and a school official’s duty to maintain discipline and protect the school community. These competing concerns, and differing standards applied to off-campus speech across circuits, as discussed infra, have drawn into question the scope of school officials’ authority. See Morse, 551 U.S. at 418 (Thomas, J., concurring) (lamenting the Court’s failure to “offer an explanation of when [Tinker] operates and when it does not”, and noting: “I am afraid that our jurisprudence now says that students have a right to speak in schools except when they do not”). Greatly affecting this landscape is the recent rise in incidents of violence against school communities. See LaVine v. Blaine Sch. Dist., 257 F.3d 981, 987 (9th Cir. 2001) (“[W]e live in a time when school violence is an unfortunate 19