Western woods, it may be an accurate statement on criminal law, but it is not true for other kinds of law: employment, education and human rights law come to mind.

Ross  was primarily a case about the "poisoned educational environment" created by his off-duty anti-semitic writings and other activities - as the excerpt I quoted above indicates.  Which means a high degree of relevance to this California school case. 

Here's another relevant excerpt from Ross v. New Brunswick School District No. 15, [SCC, 1996]:

"The school is an arena for the exchange of ideas and must, therefore, be premised upon principles of tolerance and impartiality so that all persons within the school environment feel equally free to participate.  As the Board of Inquiry stated, a school board has a duty to maintain a positive school environment for all persons served by it."