 However, he noted Justice Alito's concurring opinion, which suggests that the majority opinion might be exceedingly narrow and based on a very unusual factual context; Chemerinsky noted that if Justice Alito's opinion is seen as defining the scope of the holding, then the case establishes only the power of schools to punish speech encouraging illegal drug use rather than giving school officials great discretion to punish student speech.Thus, despite the fact that "Morse v. Frederick" is consistent with decisions from the Supreme Court and lower federal courts over the last two decades, his hope is that Chief Justice Roberts's majority opinion will be read through the prism of Justice Alito's concurring opinion, thereby having little effect on the already very limited First Amendment rights of students.Melinda Cupps Dickler noted that "The few courts that have discussed Morse have disagreed about the breadth of its holding," supporting this claim with the following citations