does not say administrators must review or censor their papers before publication. In fact, journalism education organizations, like the Journalism Education Association, argue that prior review has no legitimate educational merit and is only a tool leading to censorship. Under certain limited conditions and situations presented by Hazelwood, school administrators may be permitted prior review of (mostly high school) student publications. Until June 2005, the Hazelwood standard was not considered to apply to public college and university newspapers, a decision most recently affirmed in the 2001 appeals court decision in Kincaid v. Gibson. However, in June 2005, the 7th Circuit Court of Appeals ruled, in Hosty v. Carter, that the Hazelwood standard could apply to student publications that were not "designated public forums," and in February 2006 the Supreme Court declined to hear the students' appeal. At this time, the Hosty decision applies only in the states of Illinois, Indiana and Wisconsin. In response to the Kincaid decision, the California State Legislature passed AB 2581, which extended existing state-level statutory protection of high school student journalists to college and university students. The bill was signed into law by Governor Arnold Schwarzenegger and took effect on January 1, 2007. Controversy over alleged censorship actions has led some student newspapers to become independent organizations, such as The Exponent of Purdue University in 1969, The Daily Californian of the University of California, Berkeley in 1971, The Daily Orange of Syracuse University in 1971, The Independent Florida Alligator of the University of Florida in 1973, The Cavalier Daily of the University of Virginia in 1979, The Paisano of the University of Texas at San Antonio in 1981, and most recently The Mountaineer Jeffersonian of West Virginia University in 2008. Some states have laws which enhance the U.S. Constitution in protecting student expression documented by the Student Press Law Center. John Silber and university newspapers University administrations have learned to get around constitutional protections and effectively diminish critical student newspapers by following the example of former Boston University President John Silber, who on the advice of Harvard Law School Professor Alan Dershowitz, eliminated all funding for student newspapers in the 1970s in an attempt to suppress on-campus criticism. Silber's policy went so far as to ban student organizations funded by the university from placing advertisements in the student press. With his hands-off policy, Silber was able to eliminate the independence of The Daily News and