In Leroy v. Livingston Manor Central School District, No. 24-1241, 2025 WL 3029421 (2d Cir. Oct. 30, 2025), the Second Circuit for the first time applied the First Amendment framework for off-campus ...
Presumptively Protected. The Second Circuit initially concluded that Leroy’s message doesn’t fit within an unprotected category of speech. Although offensive, his post isn’t a true threat of violence.
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