Abstract
This article details the growth of student-based cyberbullying in the United States. The article argues that the current legal limbo of student speech issues originating in cyberspace has unfortunately led to inconsistent lower court decisions that continue to confuse as well as frustrate today's educators and parents who are required to confront student-based cyberbullying issues. The U.S. Supreme Court's 2007 decision in Morse v. Frederick, the Court's most recent student free speech case, symbolizes a missed opportunity by the United States’ highest court to develop clearer legal guidelines involving the regulation of student's off-campus speech and expression—namely, student cyberspeech.