There is no discernible judicial trend in cyberbullying cases at this point, he said. Cases went one way or another depending on the context and content of the bullying.

"It's a difficult line to tread," Hartmeister said. "We don't want to pass a law that's going to catch school administrators between First Amendment-protected rights and trying to enact an anti-bullying statute."

Eleven states have statutes that deal specifically with cyberbullying.

Legislation is not enough, however, Hartmeister said. Money needs to be put into anti-bullying training programs as well.

"As it were, legislation hasn't worked in any great way," he said. "It's whether or not schools are successfully implementing these statutes that will have a bearing on the lives of our young people."

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E-mail: estuart@desnews.com