In a decision issued on October 31, 2011, the United States Supreme Court denied review of an appeal from Avery Doninger in her free speech claim against her former Connecticut school district. See 642 F.3d 334 (2nd Cir. 2011), cert denied, 2011 U.S. LEXIS 7814 (Oct. 31, 2011). The decision not to review Doninger’s appeal in effect affirms the decision of the trial judge, U.S. District Court Judge Mark R. Kravitz that Doninger’s off-campus internet criticisms of school administrators disrupted the educational process of the school, thus subjecting her to disciplinary consequences, despite the fact that her comments were made off-campus on the Internet. While the Doninger case has not succeeded in its appeal to the U.S. Supreme Court, similar cases coming out of the Third (PA, NJ, DE, VI) and Fourth (MD, NC, SC, VA, WVA) Circuits are currently pending.