In the case of Papish v. Board of Curators of the University of Missouri et al., 1972, Barbara Papish, a graduate student at the University of Missouri was expelled for distributing an underground newspaper featuring a political cartoon and article that university officials deemed "indecent". The Supreme Court ruled in favor of Papish stating that her First Amendment rights had been violated by the university's actions. The court held that while universities have a right to enforce standards and regulations, they cannot suppress or punish speech simply because it is offensive or disagreeable. This ruling reinforced freedom-of-speech protections on college campuses across America.

In the dissenting opinion for Papish v. Board of Curators of the University of Missouri, Justice Rehnquist argued that universities should have some control over student conduct and speech to maintain an environment conducive to learning. He believed that Barbara Papish's expulsion was not a violation of her First Amendment rights as it did not involve political or ideological censorship but rather stemmed from her use of offensive language in a school publication. The university had rules against indecent speech which she violated by distributing a newspaper with sexually explicit content and vulgar language on campus. According to him, such regulations were necessary for maintaining order within educational institutions and ensuring respect among students.