The education ministry's directive to teachers in Japan to use extreme caution in choosing supplementary material in their classrooms is bound to be resisted as a violation of academic freedom. But in the United States, that argument was rejected out of hand by the Court of Appeals in 2010.

In Evans-Marshall v. Tipp City Exempted Village School District, an English teacher distributed a list compiled by the American Library Association of the "100 Most Frequently Challenged Books." She asked her ninth-grade students to investigate the reasons and then present their findings.

When a handful of parents objected to some of the books on the list, Evans-Marshall was charged with violating Ohio law, which explicitly stated that only the board of education can prescribe a curriculum.