Student bullying is one of the most frequently reported discipline issues in schools. Members of minority groups are the typical targets. These days, that most often means students whose sexual orientation or gender identity attracts the ire of others. In a school climate survey of 7,261 middle and high school students conducted by the advocacy group Gay Lesbian Straight Education Network, almost all lesbian, gay, bi-sexual or transgender students reported having been harassed in school. Two-thirds said they felt unsafe on campus because of their sexual orientation. At last count, 48 states have anti-bullying laws on their books, most mandating some kind of response or action from school districts. The two exceptions are Montana and South Dakota. But clarity and direction from state legislators is hardly a given. The subject of bullying is fraught with political, social and cultural complications, and school districts often must find their own way through the inevitable, fractious controversies.