In Harper v. Poway Community Unified School District, the Ninth Circuit Court ruled that a student could not wear a T-shirt to school bearing a statement that homosexual behavior is shameful. The court did not use the usual rationale, that such speech could disrupt school activities, but instead relied on the notion that such statements could inflict psychological harm on homosexual students. Mercurio and Morse argue that this rationale creates several new challenges for schools. Because the ruling only protects members of historically oppressed minorities, administrators must determine whether a student is part of a minority. According to Morse and Mercurio, the ruling may obligate some schools to silence only one side of potentially controversial discussions and even make theological judgments.