May school officials remove library books for reasons other than objections to the ideas contained in the books?
Yes. According to the Supreme Court in Pico, although school officials may not remove books simply because they disagree with the ideas expressed therein, they can remove books from the library if they deem them to be “pervasively vulgar” or educationally unsuitable. The issue centers on the motivation of school officials. In Louisiana, for example, the book Voodoo & Hoodoo was removed after a parent complained that it caused children to become infatuated with the supernatural. The school board eventually voted 12 to 2 to remove the book, even though a school-level committee had voted unanimously to retain it. In response, one parent sued on behalf of her child, claiming the book’s removal violated the First Amendment. A federal trial court ruled in favor of the parent. On appeal, however, the Fifth Circuit reversed, finding there were genuine factual disputes as to the school board’s motivation for removing the book. The appeals court, in ruling there would need to be further fact fin
