Deciphering the Laws of Cyberbullying Art Schouten SUNY New Paltz EDA775: NYS Education Law and Policy Dr. Jan Hammond November 30, 2010 Statement of integrity: Candidate must submit a signed statement stating: “The following is an original work and complies with the Department of Educational Administration’s Statement of Integrity.” _______________ _________________________________ Date Candidate’s signature Revised: September 2010 2 Table of Contents Section 1: Review of the System 3 Section 2: Case Law Review 5 Case One | United States v. Drew No. CR 08-0582-GW 6 Case Two | D.C. a Minor v. Harvard-Westlake School -176 Cal. App. 4th 836 6 Case Three | Commissioner’s Decision No. 15,873 – NY State (February 19, 2009) 8 Case Four | Commissioner’s Decision No. 16,105 – NY State (July 27, 2010) 8 Case Five | Commissioner’s Decision No. 16,121 – NY State (August 9, 2010) 9 Case Six | J.S. v. Bethlehem Area School District 757 A.2d 412 (2000) 10 Case Seven | Layshock v. Hermitage School District 593 F.3d 249 (2010) 11 Case Eight | J.S. v. Blue Mountain School District 593 F.3d 286 (2010) 12 Section 3: Implementation Implications 12 H.R. 1996 -Megan Meier Cyberbullying Prevent Act 14 Sec. 881. Cyberbullying 15 SB 818 (Missouri Senate) 15 Dignity for All Students Act (DASA) 16 Section 4: Advocacy Letter 17 Section 5: Communication 18 Section 6: Reflection 19 Bibliography 21 3 Section 1: Review of the System On October 16, 2006 Megan Meier took her own life after a cruel cyber hoax cultivated by a classmate’s parent went too far. After months of being tormented, harassed, and verbally abused by her classmates, Phoebe Prince, a fifteen-year-old high school freshman took her own life on January 15, 2010. On September 22, 2010 Tyler Clementi, a Rutgers University Freshman, took his own life after his roommate posted sexually implicit videos through a social network site and instant messaging systems. Megan Meier, Phoebe Prince, Tyler Clementi’s sudden and unfortunate deaths have brought attention the rise of cyberbullying or the act of bullying or harassment that “involves tormenting, threatening, harassing, humiliating, embarrassing or otherwise targeting another child, preteen or teen through usage of the internet or interactive and digital technologies” (Cyberbullying – Definition, 2010). In recent years, cyberbullying has become more prevalent in our schools. It has spawned an epidemic that is quickly spreading via text message and web post with devastating results. I-Safe Incorporated, a proponent in internet safety and education, reported that: 42% of kids have been bullied while online. o 1 in 4 have had it happen more than once. 35% of kids have been threatened online. o Nearly 1 in 5 have had it happen more than once. 21% of kids have received mean or threatening e-mail or other messages. 58% of kids admit someone has said mean or hurtful things to them online. o More than 4 out of 10 say it has happened more than once. 4 53% of kids admit having said something mean or hurtful to another person online. o More than 1 in 3 have done it more than once. 58% have not told their parents or an adult about something mean or hurtful that happened to them online (“Cyber Bullying: statistics,” 2004). With an ever-growing number of incidents, state and federal lawmakers are revamping legislation that does not currently address cyberbullying and/or internet-based harassment specifically. Without laws specifically targeting cyberbullying and online harassment on the books, the legal system has attempted to charge individuals with crimes that do not hold up in a court of law. In many cases, state legislatures have proposed new bills that will target cyberbullying in response to recent incidents. However, those laws cannot be applied to incidences that have already occurred. At the same time, school districts and lawmakers are finding themselves in a battle over students’ First Amendment rights and online speech. “With legitimate concerns about the First Amendment on one side, and equally legitimate concerns about the dangers of such conduct on the other, prosecutors are often left to shoehorn this new wave of behavior into laws created long before there was an Internet” (Levenson, 2010). Schools face a difficult challenge. Without concrete state and federal laws in place, school districts are caught in the middle of a problem without defined response tactics. Are they in violation of the First Amendment if and when they discipline a student for something said on the internet? 5 How do school districts provide students with a safe learning environment void of threats and/or harassment when the incidents in question may be occurring online and not in their school buildings? What rights does a school have to suspend or discipline a student for cyberbulllying Section 2: Case Law Review Constitution of the United States Amendment I Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; of abridging the freedom of speech, or of the press: or the right of the people peaceably to assemble, and to petition the Government of redress of grievances. The United States Supreme Court has a long-standing history pertaining to the interpretation of the first amendment as it relates to the freedom of speech. The Supreme Court has cleared defined its definition of free speech through their decision on several cases spanning several decades, including several cases that have been directly related to freedom of speech within educational institutions. With the rise of cyberbullying and internet-based harassment, one’s freedom of speech has recently be re-examined in light of the aforementioned incidents. The right of free speech in a digital society has raised many questions that did not exist five or ten years ago. The Supreme Court has not yet made a specific ruling pertaining to cyberbullying and/or internet-based harassment. However, several states have passed legislation or have proposed legislation directly related to cyberbullying. 6 Case One | United States v. Drew No. CR 08-0582-GW Shortly after befriending Josh Evans through the social network MySpace, Megan Meier began receiving cruel, insulting messages from her alleged friend. Unable to cope with the abuse of the internet-based harassment, Megan Meier took her own life on October 16, 2006. Several weeks later, a police investigation uncovered that Josh Evans was actually Lori Drew, a forty-seven-year-old parent and neighbor, who had created the profile pretending to be Josh Evans on Myspace.com in order to taunt and verbally attack thirteen-year-old Megan Meier. Nearly one year later, Lori Drew was indicted by a United States District Court Grand Jury on charges of “conspiracy and three counts of accessing protected computers without authorization in violation of the Computer Fraud and Abuse Act (CFAA), 18 U.S.C. § 1030” (“United States v.,” 2008). Following the trial, the jury found Lori Drew guilty of one count of misdemeanor Computer Fraud and Abuse Act, which was later overturned by the judge’s decision on a motion for acquittal. The judge felt that the charges did not match the crime and therefore could not sentence Lori Drew. This case and the acquittal of Lori Drew gained a great deal of media attention. Several state and federal lawmakers began to reassess current legislation pertaining to cyberbullying and proposed amendments where possible. Others sought to pass new bills entirely where current laws were lacking. Case Two | D.C. a Minor v. Harvard-Westlake School -176 Cal. App. 4th 836 A student, known in the court records as D.C., and his parents filed a lawsuit against Harvard-Westlake School accusing the district of failing to protect the student’s 7 rights under state's hate crimes laws, Civ. Code, §§ 51.7 and 52.1. D.C.’s classmates had made several online threats on a website that was created by D.C., which he used to promote his acting and singing career. The students also published several articles in the high school newspaper openly discussing the incidents and continuing to threaten D.C. The students threatened physical violence, made death threats, and also made derogatory comments about the student’s sexuality. “The students who posted the threats sought to destroy D.C.’s life, threatened to murder him, and wanted to drive him out of Harvard-Westlake and the community in which he lived” (D.C. a Minor v. Harvard-Westlake, 2010). After contacting the district, local authorities, and the FBI, D.C. was removed from the district per the recommendation of the police. However, the student newspaper immediately published an article naming the school that D.C. had transferred to as well as D.C.’s home address. The lawsuit alleged that the school district failed to provide a safe learning environment. It also accused the district of allowing its student to use school computers to make the threats. The suit outlined eleven separate charges including: Negligence; assault upon another with death threats and hate crimes; conspiracy to assault another with death threats and hate crimes; invasion of privacy; conspiracy to invade the privacy of another; defamation; conspiracy to defame another; intentional infliction of emotional distress; conspiracy to inflict emotional distress on another; negligent infliction of emotional distress; and fraud in the inducement of a contract (2009). Under the arbitration guidelines in the state of California, the lower courts awarded the school district $521,227.68 for legal fees against the parents of D.C. for bringing the lawsuit against the district. However, an appellate court citing Armendariz, supra, 24 Cal.4th 83, reversed the decision allowing the lawsuit to go forward. At this time, the lawsuit is still pending in the state of California. 8 Case Three | Commissioner’s Decision No. 15,873 – NY State (February 19, 2009) A minor, referred to as H.R., enrolled at Camden Central School District in 2003 through 2006. The student also participated on the junior varsity and varsity basketball teams. During this time, H.R. was subjected to harassment, threats, and bullying from her teammates and other students at Camden Central School District. The parents contacted the superintendent on two separate occasions requesting that the district investigate the matter. Shortly thereafter, an incident occurred off-campus where H.R. was surrounded and verbally assaulted by several students from Camden Central School District. The police were called and charges were pressed, which also lead to an investigation by the district attorney’s office. The parents of H.R. again contacted the district because they felt that the district was not providing a safe and positive educational and athletic environment. When their requests were not met, they submitted an appeal with Commissioner Mills. In Commissioner’s Decision No. 15,873, Commissioner Mills denied the petitioner’s appeal because the petitioners failed to submit adequate paperwork or did not submit the correct paperwork according to NYCRR. Mills made no mention of cyberbullying therefore avoiding the situation all together. Case Four | Commissioner’s Decision No. 16,105 – NY State (July 27, 2010) E.S., a student at Lynbrook Union Free School District, used his cell phone camera to record his Italian class while his classmates asked irrelevant questions to purposely interrupt class. He then uploaded the video and shared it with his classmates on Facebook. 9 The parents of E.S. received a letter several days later stating that E.S. would be suspended for five days for providing the camera used to record the class and then posting the video on Facebook. After an informal meeting with the parents, the principal reduced the suspension to three days. The parents of E.S. appealed the suspension citing that they were not granted due process. Although Commissioner Steiner felt that the parents were not properly notified of their due process rights, he stated that the student still engaged in activities that disrupted the normal operation of the school community because his actions subjected “a faculty member to embarrassment and ridicule, thereby undermining authority and ability to maintain classroom discipline, as well as by becoming a major topic of conversation throughout the school, affecting its normal operation” (No. 16105, 2010). Therefore, Commissioner Steiner upheld the suspension and refused to esponge the suspension for the student’s permanent record. Case Five | Commissioner’s Decision No. 16,121 – NY State (August 9, 2010) During the 2009-2010 school year, a minor referred to as K.I. was involved in an online argument with another student, in which they exchanged insults and threats on Facebook. A third student informed the building principal of the incident who conducted an investigation and interviewed all involved parties. During this investigation, K.I. admitted that she had been involved in the online argument and had made threatening remarks. Following the investigation, the principal met with the petitioner to discuss her findings and to inform him that K.I. would receive one day of in-school suspension. Dissatisfied with the principal’s decision, the petitioner first appealed the decision with the superintendent and later with Commissioner Steiner. 10 The petitioner argued that the school district exceeded their jurisdiction by disciplining his child for comments made on Facebook outside of school. After reviewing the appeal, Commissioner Steiner dismissed the case on the grounds that the in-school suspension did not violate §3214, also known as a superintendent’s hearing. The commissioner made no mention of the incident that happened on Facebook or the jurisdiction of the principal in said matter. Case Six | J.S. v. Bethlehem Area School District 757 A.2d 412 (2000) J.S., an eight grade student, created a personal website from his home computer entitled “Teacher Sux,” in which he posted derogatory comments about his math teacher, Mrs. Fulmer, and building principal, Mr. Kartsotis. On one particular page, the student listed several reasons why Mrs. Fulmer should be killed and encouraged students to donate twenty dollars that would be used to pay for a hit man. Additional pages depicted images of Mrs. Fulmer being decapitated and continued to use derogatory commentary to depict the student’s dislike for the teacher. Upon being informed of the website, the district conducted a fact finding investigation that lead to the suspension of J.S. for three days stating that the student had violated the code of conduct by making threats, harassing a teacher, and disrespect of school personnel. The three-day suspension was extended to a ten-day suspension following a superintendent’s hearing. Following a board investigation, the district expelled J.S. from the Bethlehem Area School District. The parents of J.S. filed a lawsuit stating that the school district had violated J.S.’s First Amendment rights. The student’s lawyers also argued that the threats posted on the website were not actual threats; they were juvenile exaggerations that were never meant 11 to be viewed by school officials. After reviewing the case, the Pennsylvania Supreme Court decided in favor of the school district. In citing Tinker v. Des Moines Independent Community School District, the courts did not find a direct threat in the comment made on the student’s website. However, they felt that the website “disrupted the educational process by making a teacher at the school feel threatened and negatively affecting other students' perceptions of school staff” ("Judge upholds expulsion," 2000). Case Seven | Layshock v. Hermitage School District 593 F.3d 249 (2010) Justin Layshock, a student at Hermitage School District, created a derogatory MySpace profile of his high school principal, in which he used phrases such as "big faggot," "big hard ass," and "big dick” when completing the standardized personal profile. Although Justin Layshock created the parody profile from a home computer, his classmates used school computers to access MySpace, comment on the profile, and share the information with other students. When school officials learned of the profile and its creator, they suspended Justin Layshock for ten days in addition to transferring him to an alternative school program and forbidding him from participation in his high school graduation later that spring (CMLP Staff, 2007). In response, Justin Layshock and his parents sued Hermitage School District for violating Justin’s First Amendment and Fourteenth Amendment rights. After reviewing the case, the courts sided with Justin Layshock stating that the school district had violated the student’s First Amendment rights. In cases involving offcammpu speech, the court found that the school must demonstrate an appropriate nexus between the speech and the school. “The district court concluded that the weight of student speech case law favored the view "that school officials' authority over off-campus 12 expression is much more limited than expression on school grounds” ("Layshock v. hermitage," 2007). The courts sited Tinker v. DesMoines, 393 U.S. 503 89S S. CT. 733 (1969), in which they felt that the parody profile did not establish a significant nexus that disrupted the school or its operations. However, the courts ruled against Layshock in terms of the Fourteenth Amendment ruling that the district followed set policies in discipline the student. Case Eight | J.S. v. Blue Mountain School District 593 F.3d 286 (2010) Two eighth grade students created a fake MySpace account making derogatory statements of their principal, James McGonigle. Although the principal was not mentioned by name, the students posted the principal’s photograph, which was copied from the district’s webpage. “According to court documents, the profile characterized the principal as a sex-obsessed pedophile, and it was laced with profanity and other negative comments about McGonigle and his family” (CLMP, 2008). Another student approached Principal James McGonigle and informed him of the MySpace profile that had been created. The student supplied the principal with a printed copy of the profile that was brought in from home. Upon discovering who created the profile, the district suspended J.S. and another involved student for ten days stating that the students violated the school’s Code of Conduct and the Acceptable Use Policy. The parents of J.S. sued Blue Mountain School District stating that the district violated their child’s First Amendment rights. They argued that “the school could not constitutionally punish her for out-of-school speech that did not cause a disruption of classes or school administration” (2008). The courts upheld the district’s decision to discipline the student for her vulgar, derogatory speech although it occurred off-campus. 13 Again, the courts cited Tinker v. DesMoines in making their decision. As stated by the courts in J.S. v. Blue Mountain School District 593 F.3d 286 (2010), “Electronic communication allows students to cause a substantial disruption to a school’s learning environment even without being physically present.” Section 3: Implementation Implications Until state legislatures and/or the federal government establish guidelines pertaining to cyberbullying, districts need to take a proactive stance in the matter. District leaders need to review their curriculum and develop a P-12 initiative that incorporates digital citizenship, internet safety, and cyberbullying throughout the system. The program should incorporate all members of the school community including students, teachers, administrators, related programs, and family members. In the 21st century digital world, we need set guidelines that promote digital citizenship and responsibility. If we cannot depend up our state and federal legislatures to establish guidelines, then we must take it upon ourselves to set policies and procedures that protect our students from the dangers of cyberbullying. Social Implications Facebook, one of the most popular social networking sites, has over 500 million active users. Those users spend over 700 billion minutes per month on Facebook interacting with “friends.” There is an additional 200 million users who access Facebook on mobile devices. These users are twice as active as non-mobile users (Press Room, 2010). Our students are more connected and more socially involved then most non-digital natives realize. With the growing popularity of Facebook, Twitter, and other social networking applications the frequency of incidents are also increasing. Districts need to 14 accept the impact of social networks and their role in the students’ lives. Rather than fighting against the current, districts need to adopt programs that will teach proper use and the repercussions of misuse. Cultural Implications There is a clear disconnect between our current students, known as Digital Natives, and their teachers. There is a disconnect between students and teachers; there is a disconnect between students and curriculum. “Our Digital Immigrant instructors, who speak an outdated language (that of the pre-digital age), are struggling to teach a population that speaks an entirely new language” (Prensky, 2001). As we develop new programs to counter cyberbullying and promote digital citizenship, we also need to develop programs to educate our teachers who lack the understanding or classroom skills to involve engage Digital Natives in the learning process. “Digital Immigrant teachers assume that learners are the same as they have always been, and that the same methods that worked for the teachers when they were students will work for their students now” (2001). We cannot expect that our 21st century students will adapt to our outdated 19th century model. Economic Implications “During the first decade of the 21st Century, U.S. broadband Internet connectivity by households has increased dramatically as its importance to our economy and way of life has grown” (Department of Commerce, 2010). As technology infuses into our daily lives, the number of mobile devices and computer technology will continue to increase, especially among our students. In order to keep up with a changing society, districts will also need to change their policies on technology and its implementation in the classroom. 15 Rather than powering down, we need to teach our students how to stay wired, but stay wired responsibility and respectfully. In doing so, districts will need to incorporate additional professional development opportunities into their annual plans and annual budgets. Political/Legal Implications State and federal legislatures have taken a reactive stance to cyberbullying and internet-related crimes. H.R. 1996 -Megan Meier Cyberbullying Prevent Act Following the suicide of Megan Meier, Representative Linda Sanchez introduced bill H.R. 1996 – Megan Meier Cyberbullying Prevent Act on April 2, 2009. The bill is an amendment to title 18 of the United States Code in relation to cyberbullying. The amendment states: Sec. 881. Cyberbullying (a) Whoever transmits in interstate or foreign commerce any communication, with the intent to coerce, intimidate, harass, or cause substantial emotional distress to a person, using electronic means to support severe, repeated, and hostile behavior, shall be fined under this title or imprisoned not more than two years, or both (111th U.S. Congress, 2009). A Congressional committee is still reviewing this legislation. SB 818 (Missouri Senate) In response to the suicide of Megan Meier and the acquittal of Lori Drew in the case United States v. Drew, The Missouri Senate introduced and passed SB 818, which modified previous legislation related to stalking and harassment. Under the original law, harassment was considered a Class A misdemeanor. However, the new bill outlined that any individual twenty-one years of age or older who frightens, intimidates, or causes 16 emotional distress to a person seventeen-years of age or younger will be charged with a Class D felony. The bill, which was signed by Governor Matthew Blunt signed the legislation into law on June 30, 2008, also required school boards “to create a written policy requiring schools to report harassment and stalking committed on school property to local police, including such done via the Internet” (IBLS, 2008). Dignity for All Students Act (DASA) In September 2010, New York State Governor Patterson signed the Dignity for All Students Act, which provides tools for schools districts to incorporate in order to protect their students from bullies. The Dignity for All Students Act set specific guidelines that school districts must address by July 1, 2012. Those guidelines include: Revise their codes of conduct and adopt policies intended to create a school environment free from harassment and discrimination; Adopt guidelines to be used in school training programs to raise awareness and sensitivity of school employees to these issues and to enable them to respond appropriately; and Designate at least one staff member in each school to be trained in nondiscrimminator instructional and counseling methods and handling human relations (Governor Paterson signs, 2010). 17 Section 4: Advocacy Letter Andrew Cuomo New York Governor-Elect State Capitol Albany, NY 12224 Art Schouten 71 Meyerhoff Road Hurleyville, NY 12747 November 26, 2010 Dear Governor-Elect Andrew Cuomo, Many districts are having problems addressing and/or preventing the impact of cyberbullying on our students. I see the need for clearly defined laws that address cyberbullying and its impact on our students. A possible solution that we foresee is the implementation of the following: Restructure current state laws that address harassment to include language directly related to cyberbullying. Provide literature and programming for school districts and community members to outline the new laws related to cyberbullying and the consequences for infractions. I appreciate your time and consideration and hope that I have addressed this growing matter that has evolved in recent years due reliance upon emerging technologies, social media, and 21st century skills. Sincerely, Art Schouten 18 Section 5: Communication Faculty, Staff, and Administration It is vital that all faculty, staff, and administrators are fully aware of any and all changes to the law that directly impact the school district. As the board of education develops new policies to address cyberbullying and the adoption of The Dignity for All Students Act, district personnel must be made aware of said policies and their impact on the school district. Similarly, and changes to the law that directly impacts cyberbullying should also be addressed during Opening Day meetings and/or additional Superintendent’s Professional Development Days. Additional literature can and should be distributed as needed. Parents and Community Members Working with the PTO and local BOCES organization, parents and community members should be informed of changes to board policies and state law so that they are aware of how the district will handle any and all violations. Local Law Enforcement Schools districts and local law enforcement agencies can and should work together to communicate changes to the law and its impact on the students. An open channel of communication should be created between the law enforcement agencies and the school district to further prevent issues from escalating. NYS Commissioner of Education; NYS Senate and Assembly Local school districts and BOCES organizations should work jointly to advocate for laws pertaining to cyberbullying and student harassment. The laws should be clearly stated and incorporate language that outlines the districts’ responsibilities. For example, 19 the law should outline districts as mandated reports and/or have the ability to discipline students for online language that may occur outside of the regular school day as long as it directly affects the students of said school district. Section 6: Reflection As the Lead Technology Integration Specialist for Orange-Ulster BOCES and its seventeen component school districts, I knew that cyberbullying was a growing concern among district administrators and educators. My conversations with teachers and administrators from various districts lead me to discover that we had very little in place in terms of educational programs, policies, or procedures that addressed cyberbullying. Although some districts had implemented K-5 internet safety programs, they failed to incorporate programs into their middle school and high school curriculum. That being said, I began taking a look into current case law. I wanted to know what I didn’t know at the start. I wanted to know how stance the federal and state governments had taken on cyberbullying. I wanted to know what stance the courts had taken as well. What laws, if any, were in place? How have the courts handled cyberbullying cases when they have come before the judge? Unfortunately, I found that there were very few laws in place. Some states had adapted their current law system to include “cyberbullying” under their definitions of harassment. However, the language and implications were still difficult to follow, especially in terms of school district involvement/responsibility. At the same time, I quickly learned that the courts were far from decisive on the matter. Some upheld the First Amendment; others went against it. Some decided in favor of the student; others did not. The same courts reviewing similar cases decided differently in each case. Both Commissioner Mills and Commissioner Steiner avoided the cases all 20 together. The commissioners found other items within the cases to base their decisions on without having to refer to cyberbullying or online-harassment. The general consensus was that school districts had the right to discipline students outside of the regular school day for language posted on social network sites and/or other related websites. If a situation arises in one’s school district, the district has the right to discipline the student, especially when the language posted online disrupts the school day. Although specific laws still don’t exist, it is better to discipline a student and be sued then to not do anything and find yourself in the middle of a media circus after another student suicide. In the end, I now know a lot more than I knew going into this. I am also working with Orange-Ulster BOCES and its component districts to inform their staff as well as their community members, specifically parents. In the coming months I will be working with various districts to establishing parental portals and parent information sessions surrounding cyberbullying, internet safety, and digital citizenship. In my opinion, it’s better to be proactive and take an active stance against cyberbullying than it is to take a reactive stance after an incident occurs in our local area. 21 Bibliography Case Law D.C. a Minor v. Harvard-Westlake School -176 Cal. App. 4th 836 J.S. v. Bethlehem Area School District 757 A.2d 412 (2000) J.S. v. Blue Mountain School District 593 F.3d 286 (2010) Layshock v. Hermitage School District 593 F.3d 249 (2010) United States v. Drew No. CR 08-0582-GW Commissioner’s Decisions Commissioner’s Decision No. 15,873 – NY State (February 19, 2009) Commissioner’s Decision No. 16,105 – NY State (July 27, 2010) Commissioner’s Decision No. 16,121 – NY State (August 9, 2010) Additional Resources 111th U.S. Congress, House of Representatives. (2009). Megan Meier cyberbullying prevention act (H.R. 1966). Retrieved from http://www.govtrack.us/congress/billtext.xpd?bill=h111-1966 CLMP, Staff. (2008, December 12). Blue mountain school district v. j.s.. Retrieved from http://www.citmedialaw.org/threats/blue-mountain-school-district-v-js#description Cyberbullying -definition. (2010, August 9). Retrieved from http://lawbrain.com/wiki/Cyberbullying Cyber bullying: statistics and tips. (2004). 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Student Press Law Center, XXI(3), Retrieved from http://www.splc.org/news/report_detail.asp?id=450&edition=4 Layshock v. hermitage sch. dist., no. 06-116 (july 10, 2007). (2007, July). Retrieved from http://www.nsba.org/SecondaryMenu/COSA/Search/AllCosaDocuments/Layshockv HermitageSchDistNo06116July102007.aspx Levenson, L.L. (2010, September 30). What isn't known about suicides. Retrieved from http://www.nytimes.com/roomfordebate/2010/09/30/cyberbullying-and-a-studentssuiccidewhat-isnt-known-about-suicides Prensky, M. (2001). Digital natives, digital immigrants. On the Horizon, 9(5), Retrieved from http://www.google.com/url?sa=t&source=web&cd=1&ved=0CBwQFjAA&url=htt p%3A%2F%2Fwww.marcprensky.com%2Fwriting%2FPrensky%2520%2520Digit al%2520Natives%2C%2520Digital%2520Immigrants%2520%2520Part1.pdf&rct=j &q=digital%20natives%20statistics&ei=OXTuTO7sF4Odlgfqy4z7DA&usg=AFQj CNEUHeiX8ghPYUPXKPWbM4xzAljIpg&sig2=Gv_S6Z5j_S7HQGIOJZZwDAcad=rja Press Room. (2000). Retrieved from http://www.facebook.com/press/info.php?statistics United states v. drew. (2008, September 16). Retrieved from http://www.citmedialaw.org/threats/united-states-v-drew