This decision gives school officials the authority to regulate lewd and offensive conduct by students as a way of teaching values and to discipline students so as to protect the school education mission from the appearance of compromise. There is now a sufficient base of State and Federal cases to analyze the impact of these rules on school discipline cases. Two distinct notions of "Bethel discipline" have emerged. In the first, schools impose a higher standard of conduct and as a result punish inappropriate behavior, even off-campus behavior, when the student appears to be representing the school. In the second notion, school-sponsored activities are subject to greater control by school authorities than unsponsored activities, and participating students are held to a higher standard of conduct. The first of the two areas is the most far-reaching and controversial, because school officials hold students accountable for their conduct as a condition for maintaining some ongoing relationship. The relationship, in most cases, involves an extracurricular activity that draws attention to students and makes them unofficial agents for the school in the community. 7 notes