History shows that the high school press suffers through cycles that reflect economic factors and cultural climates within communities, states, and the nation. The direction of that cycle in the 1960s and early 1970s was toward more open, free-flowing information by a vigorous student press, but those economic and cultural signs now are pointing toward a period of increasing censorship and narrowing of the guidelines governing what is publishable, much like in the 1950s. The key to the maturing of the student press was the enthusiastic teacher/adviser that appeared in the early 1970s, who no longer viewed the newspaper product with proprietary interest. In 1974, the Commission of Inquiry into High School Journalism found that unconstituional and arbitrary restraints were a matter of school policy--stated or implied--in all areas of the country. In the face of increasing censorship, students and faculty advisors are taking their cases to court. While there is no adequate body of law covering the student press issue, there are a few certainties: (1) the courts have consistently ruled that administrators cannot control the content of student publications; (2) private schools are not covered by the forum theory that underlies these rulings; (3) obscene works, libelous works, and works that would cause a "substantial disruption" in the schools can be legally censored; and (4) in all censorship cases, the "burden of proof" rests on the censor. (HTH)