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This paper examines the degree to which the Supreme Court case, Island Trees School District v. Pico informs public school board actions regarding school library book censorship. Using a unique dataset in which we collected a decade of book challenges, we examine school district behavior using Mazzoni’s arena model. This approach is novel as Pico’s influence has yet to be interpreted conceptually in scholarship. We find that Pico is unevenly understood and applied at the school board level. We attribute this finding to multiple factors: difficulty discerning school board member motives, complex political networks at school board decision sites, and parent influences on decision making processes. We discuss the implications for students’ First Amendment rights in public schools.