In Hosty v. Carter the US Court of Appeals for the Seventh Circuit in 2005 held that "Hazelwood's framework applies to subsidized student newspapers at colleges as well as elementary and secondary schools," unless the student publication is a "public forum."   The case arose from efforts of the dean at Governors State University to exercise prior review when the student newspaper criticized the administration.  The district court had ruled that the Hazelwood decision did not apply to post-secondary schools, a position that has also been taken by the US Court of Appeals for the First Circuit Court.  The Tenth and Eleventh Circuits have, like the Seventh Circuit, ruled that it does apply to colleges and universities. 

(The US Court of Appeals for the Seventh Circuit has jurisdiction over Indiana and Illinois as well as Wisconsin.  Tenth Circuit rulings apply to Wyoming, Utah, Colorado, New Mexico, Kansas and Oklahoma; Eleventh Circuit rulings apply to Florida, Georgia and Alabama; First Circuit rulings apply to Massachusetts, New Hampshire, Maine, Rhode Island and Puerto Rico). 

The US Court of Appeals for the Seventh Circuit ruled in 2008 that a child welfare worker who conducted an examination of the bodies of two children in a private school without parental consent had violated their Fourth Amendment rights. The social worker was searching for marks indicating that they had been beaten by their stepfather, but did not find any. The court ruled that children have a reasonable expectation of privacy in a private school.