According to ABC News, a study of Yale University shows more than 160,000 kids stay at home in order to avoid cyber-bullying, and approximately 4,000 young teenagers choose to end their lives each year due to frequently being bullied four to nine times in the Internet (New Hampshire Union Leader, 2014). Cyber-bullying becomes a serious social problem, causing severe psychological harms and even death. At the same time, when addressing and punishing cyber-bullying, courts and public schools usually meet a conflict with students’ free speech right. Due to lack of unified laws from the Supreme Court, lower courts and public schools usually rely upon the guidance established in “1969 Tinker v. Des Moines Independent Community School Districts,” the case in which the Supreme Court upheld students’ on-campus free speech right but with two exemptions. A student’s speech can be regulated only if the speech could cause “substantial disruption” and “collision with others’ right.” Due to omnipresent nature of the Internet, Tinker’s standards, especially on-campus limitation, become ambiguous and ineffective when dealing with cyber-bullying that happens without a geographical boundary. In the American legislative field, scholars have a harsh debate upon how Tinker can continue to protect students’ on-campus free speech right yet constitutionally addresses cyber-bullying by its standards. In attempt to expand the effectiveness of Tinker, Jesse Snyder in Texas Wesleyan School of Law suggests to reasonably broaden Tinker’s scope of “substantial disruption” to address off-campus online misconducts that impact upon school environment (2012). Araujo Walter proposes to combine two prongs to lend school authority to examine disruptive speech impinging with others’rights as a type of disruption (2013). Allison Belnap advocates “True Threat” approach, a test combing other precedents regulating students’ speech, to identify several unprotected off-campus online [removed]2012). Although each of above policies endeavors to facilitate Tinker to adapt into changing communication environment before a specific law is established from the Supreme Court, the most effective way is to take advantage of the second Tinker’s prong, “impingement upon others’ right,” to avoid distinguishing vanished boundary between on and off campus speech, ambiguity in definition of “substantial disruption” and “chilling effect” raised by combining application with other precedents, as advocated by Aaron J. Herish in University of Iowa College of Law (2013). According to Cyberbullying Statistics, around 95% of American teenagers between ages of 12 to 17 have at least once the Internet communication, and 80% of those teenagers frequently utilize social media and instant messaging applications in their smartphones to get involved into instant interactions with other users regardless of whether staying campus or not (2013). The instantaneous nature of the Internet persists blurring the boundary of school gates, and severe consequences resulted from disruptive online expression can be brought into school environment. Under the original framework, Tinker is tied to on-campus speech, so it is hard to regulate cyber-bullying that happens non-geographically. One of the policies to solve the problem is to expand the effectiveness of Tinker’s regulation to reach outside of school houses to adapt into omnipresent quality of cyber-expression, as advocated by Snyder (2013). The policy directly allows school administrators to utilize Tinker’s two prongs to determine whether a student’s online speech, regardless of originating from on or off-campus, exempts from the protection of the First Amendment. This is an easiest and applicable method due to its simplicity that does not require adding more restrictions or new interpretations into Tinker. After the extension, cyber-bullying can be addressed under “substantial disruption.” Although Snyder’s policy improves Tinker’s applicability in the digital age, it does not cover the problem on how to define “substantial disruption.” Also, as mentioned by David R Hostetler (2014), “‘substantial disruption’ is a qualitative standard that requires evidence of significant one-time or cumulative impact, not just that some impact has occurred.” When using Tinker, courts and public schools have to collect solid evidence to prove that cyber-bullying cause “substantial disruption.” Because cyber-bullying usually targets individuals, it barely influences upon school’s normal operation and leaves obvious physical evidence. In other words, even though expansion of Tinker’s effectiveness enables courts and public schools to go beyond the geographical limitation, the high standard and ambiguity in definition of “substantial disruption” still prohibit school administrators regulating cyber-bullying and fear violation of students’ free speech right pr