Before we get to Brandon, let's detour to Bethel School Dist. No. 403 v. Fraser (1986). Matthew Fraser gave this nomination speech for a friend who was running for high school vice-president:
I know a man who is firm—he's firm in his pants, he's firm in his shirt, his character is firm—but most … of all, his belief in you, the students of Bethel, is firm.
Jeff Kuhlman is a man who takes his point and pounds it in. If necessary, he'll take an issue and nail it to the wall. He doesn't attack things in spurts—he drives hard, pushing and pushing until finally—he succeeds.
Jeff is a man who will go to the very end—even the climax, for each and every one of you.
So vote for Jeff for A.S.B. vice-president—he'll never come between you and the best our high school can be.
You'll note that none of the words here were what one might colloquially call "vulgarities," but the Court concluded that the school was entitled to discipline Fraser for engaging in "vulgar" speech. (Some language in the opinion suggests that the doctrine might be limited to speech before audiences at school assemblies, but courts have generally read it more broadly than that.)
