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Graduate student Christopher Brown sued the University of California at Santa Barbara after his master’s degree was withheld by university officials because he included a "disacknowledgments" section in his thesis that criticized administrators and government officials without his thesis board’s approval. That section began: "I would like to offer special Fuck You's to the following degenerates for being an ever-present hindrance during my graduate career." It then named the dean of the graduate school, former California Governor Wilson, the managers of Davidson Library, and Regents of the University of California as having been particularly unhelpful.

Christopher Brown sued the University of California at Santa Barbara claiming that his First Amendment rights were violated. A district court held that Brown’s First Amendment rights were not violated and he appealed, but a three-judge federal appellate court panel ruled that colleges can limit student speech in academic work after a graduate student attempted to criticize administrators in his master’s thesis. In its 2-1 decision, the U.S. Court of Appeals for the Ninth Circuit upheld the district court’s ruling that stated a college can expect students to follow its guidelines for written work. In its opinion, the Ninth Circuit explained that U.S. Supreme Court’s 1988 decision in Hazelwood School District v. Kuhlmeier could be applied to college free-speech cases concerning curriculum. (In Hazelwood, the Court held that high school officials did not violate the rights of students when prohibiting the publication of newspaper stories that were deemed objectionable.)

In March 2003, the Supreme Court of the United States declined to hear Brown's appeal.