Alternative or Underground (Unofficial) Student Publications Burch v. Barker, 861 F. 2d 1149 (9th Cir. 1988) Schools may not have a blanket pre-distribution review policy based on an "undifferentiated fear" that unofficial student publications might cause a disruption of the orderly operation of the school or cause harm to students; However, a narrowly drawn policy requiring review for specific identified content might be constitutional. Also see, BARCIK v. KUBIACZYK, 321 Ore. 174; 895 P.2d 765; 1995 Ore. LEXIS 42 (Or. 1995) Challenge to prior review policy for unofficial newspapers in Oregon school district.