Case: 12-60264 Document: 00513162565 Page: 20 Date Filed: 08/20/2015 No. 12-60264 reality that educators must confront on an all too frequent basis”.). School administrators must be vigilant and take seriously any statements by students resembling threats of violence, Ponce, 508 F.3d at 771, as well as harassment and intimidation posted online and made away from campus. This now- tragically common violence increases the importance of clarifying the school’s authority to react to potential threats before violence erupts. See Morse, 551 U.S. at 408 (pressing that dangerous speech, such as speech advocating drug use, is substantially different from the political speech at issue in Tinker, because it presents a “far more serious and palpable” danger than an “undifferentiated fear or apprehension of disturbance” or “a mere desire to avoid the discomfort and unpleasantness that always accompany an unpopular viewpoint” (citation and internal quotation marks omitted)); see also Ponce, 508 F.3d at 772 (“School administrators must be permitted to react quickly and decisively to address a threat of physical violence . . . without worrying that they will have to face years of litigation second-guessing their judgment as to whether the threat posed a real risk of substantial disturbance.”). In the light of these competing interests and increasing concerns regarding school violence, it is necessary to establish the extent to which offcampus student speech may be restricted without offending the First Amendment. Our holding concerns the paramount need for school officials to be able to react quickly and efficiently to protect students and faculty from threats, intimidation, and harassment intentionally directed at the school community. See, e.g., Morse, 551 U.S. at 425 (Alito, J., concurring) (“[D]ue to the special features of the school environment, school officials must have greater authority to intervene before speech leads to violence.”); Lowery v. Euverard, 497 F.3d 584, 596 (6th Cir. 2007) (“School officials have an 20

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