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A United States District Court in Wisconsin granted a student's case against Northeast Wisconsin Technical College involving the passing of little holiday notes.

The student, Polly Olsen, was passing out Valentine's Day cards with Bible verses and biblical messages on them to fellow students and staff at NWTC last year. This was part of a tradition Olsen had practiced as a child with her now-deceased mother.

A security officer stopped Olsen and informed her that she was violating the college's public assembly policy. Olsen contests this and says that NWTC infringed on her First Amendment rights.

The district court has granted Olsen's summary judgment and instructed that Olsen receive a sum of $1 for the violation by NWTC of her First Amendment rights, which included handing out Valentine's cards.

The judge ruled that the biblical Valentine's notes were similar to "handbilling" but not "handbilling in the traditional sense," and a "constitutionally protected form of expression." The judge followed that the messages Olsen was handing out to individuals were not for the general public but for specific people, therefore she was not using a public forum. None of Olsen's messages were obscene, and she was not trying to rally anyone, as the court showed.