Doninger/Wisniewski Two-Part Test for Off-Campus Speech

1) It is reasonably foreseeable that the speech would come to the attention of school authorities;

and

2) School authorities could reasonably forecast that the speech would cause substantial disruption.

The first part of the test creates a connection between off-campus speech and the public school to demonstrate that even though the speech occurred off-campus, it was likely to reach the school. The second part of the test incorporates the Tinker substantial disruption standard.