Sigma Chi Fraternity Case Summary

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In Iota Xi Chapter of Sigma Chi Fraternity v. George Mason University, both the trial and appellate courts found that Delta Chi Fraternity’s skit qualified as expressive entertainment and was protected by the First Amendment. The contested speech occurred during a philanthropy event that involved members of the Fraternity dressing up as women in an “Ugly Women Contest” (pg. 1). One of the men dressed up as, “an offensive caricature of a black woman” (pg. 1). To determine whether the First Amendment protected the speech, the court looked at if the speech in question qualified as expressive entertainment. The expressiveness of the speech is important because, “unquestionably, some forms of entertainment are so inherently expressive as to fall …show more content…

On the other side, the institution argued that the speech in question was mindless, lacking artistic expression and that the First Amendment protections are only applicable if the entertainment has a message likely to be understood by a “particular audience” (pg. 4). To examine whether or not the speech was protected and thus granted First Amendment protection, the court utilized an expressive conduct test from Texas v. Johnson. In this case, it was important to note that the entertainment quality, or lack thereof, is not examined through the test. The test states that expressive conduct occurs when “the intent to convey a message can be inferred from the conduct and the circumstances surrounding it” (pg. 4). The circumstances surrounding this particular event are that it was a philanthropic event that partnered fraternities and sororities together to raise money for charities. The test qualified the speech as expressive because there was an intent to give a message that could be picked up on by the conduct and circumstances around the speech. Additionally, the court cited Texas v. Johnson again to show that First Amendment protections prevent the government from punishing expressive content just because it disapproves of what is being said. This ruling defeated the institution's argument that the speech was not protected because it was “mindless

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