While education is an American constitutional value, the opportunity to pursue an education--particularly to pursue a quality education--is meaningless unless the student is able to pursue his/her educational rights in an environment that is both safe and secure. If students are subjected to sexual and racial harassment, to physical violence, to bullying and intimidation, to a culture of illegal drugs, and/or other dangers, then learning cannot take place. Outstanding instructors, state of the art equipment, newly issued textbooks, small classes, and large financial expenditures are irrelevant to the child who is terror stricken by attending school. Thus, if the American constitutional value of education is to have any substantive meaning, the government must insure that there is a safe and secure learning environment. This article focuses on the role of the American courts in enforcing educational safety and security. That is, this Essay explores the role of the judiciary in insuring that all children have a safe and secure environment in which to learn. Its central thesis is that the American courts--particularly the Supreme Court of the United States---have a mixed record in this regard.