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In Board of Education, Island Trees Union Free School District No. 26 v. Pico (1982), for the first and only time, the U.S. Supreme Court addressed the removal of books from public schools' libraries. At issue was whether a school board's decision to remove nine books from school libraries should have been limited by the First Amendment. Although the decision in Pico was a fractured one, with seven of the nine Justices writing separate opinions, it does provide guidance for the removal of library books. Under Pico's plurality, the motivation for the book removal is the central factor in determining constitutionality. If the purpose of removing books is purely to eliminate diversity of ideas for nationalistic, political, or religious reasons, then the action is ...

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