Question

Under what circumstances with protest of the students in tinker versus Des Moines be deemed unprotected speech

Answer 1

Judging by the opinion, if the students in Tinker v. Des Moines had done more than wear black armbands and had instead engaged in "disruptive" speech that got in the way of their classmates learning, they likely would have been ruled against. This is the type of analysis that the Court had to do in cases like the infamous "Bong Hits 4 Jesus" case wherein a student relayed that message during a school event.