At least 13 US states have passed laws requiring school districts to develop policies on cyberbullying, the Washington Post reports, and "a handful of other states" are considering the same. Arkansas, Delaware, Idaho, Iowa, Michigan, Minnesota, Nebraska, New Jersey, Oklahoma, Oregon, South Carolina, and Washington are among those with laws already in place, and California just joined them at the turn of the year, San Francisco's KCBS radio reported. Developing cyberbullying policy is not easy for schools because of the need to balance students' protection with their free-speech rights. Such policymaking becomes a problem, civil liberties advocates say, when schools "try to control what students say outside of school," the Post reports. Where they can step in, courts have said, is when what students post off-campus disrupts the learning process at school or causes peers to avoid going to school out of fear. "John Halligan, whose son Ryan took his life in Essex Junction, Vt., after many years of bullying, some online, applauded the national movement to enact cyber-bullying laws. But, he said, laws alone cannot stop the problem," according to the Post. See also "Cyberbullying better defined," "Teaching students to help stop cyberbullying," and "Anti-cyberbullying teachable moment."