Joyner v. Whiting

477 F.2d 456 (1973)

In 1971, the Campus Echo—the student newspaper at the historically black university, North Carolina Central University—published front-page content “expressing some considerable dissatisfaction” with the increasing number of white and non-black students at the university. The newspaper also said that it would stop running “white” advertisements. University President Albert Whiting, believing that the Campus Echo did not “either meet standard journalistic criteria nor represent fairly the full spectrum of views on the campus,” determined that student-fee funds would no longer be allocated the newspaper.

Editor-in-chief Johnnie Edward Joyner and Harvey Lee White, president of the Student Government Association, sued Whiting. The Fourth Circuit Court of Appeals ruled that the Constitution protects the press from from being imposed with censorship by means of “direct or indirect financial assistance.”