While some legislatures have taken steps to address cyberbullying, school administrators still are grappling with their role in curbing cyberbullying that occurs off campus. Some schools have implemented anti-bullying programs and social-emotional development curricula and used anti-bullying applications, such as anonymous reporting tools. "Until the Supreme Court takes up this issue, the law still lags behind the reality of how we live," Francisco Negron, chief counsel for the National Association of School Boards, said.

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