The Supreme Court finally attempted to set some limits on student First Amendment rights in the 1986 case of Bethel School District No. 403 v. Fraser. Matthew Fraser made a speech at an assembly full of obscenities and innuendoes. When school officials attempted to discipline him for his speech, he sued. The Supreme Court sided with the school.

The Court found that Fraser had failed the “substantial disorder” part of the Tinker test. Chief Justice Warren Berger, writing for the majority, said that schools have a responsibility to instill students with “habits and manners of civility as values.” The effect of Fraser’s speech, suggested Berger, was to undermine this responsibility; therefore, he did not receive First Amendment protection for it. Not only can schools take into account whether speech is offensive to other students, said Berger, “the undoubted freedom to advocate unpopular and controversial views in schools and classrooms must be balanced against the society’s countervailing interest in teaching students the boundaries of socially appropriate behavior.” Bethel served notice that the Supreme Court saw limitations on student free speech rights. The next big school First Amendment case decided by the court served to emphasize that point.