Let me start by saying that I love to talk and was guilty of passing a few notes in class during my days in middle school. The trick was to fold it just right so that tape was not involved in sealing the hand written letter and passing the note when the teacher was not looking.
That being said, I am a big girl now and have my own classroom. I watched out of the corner of my eye as one of my university field experience students found a student with a letter. He brought it directly to me and was quite affronted that one of my students had a note. I smirked.
When does note passing require a consequence?
I think that note passing is a right of passage at the middle school. I don't get too bent out of shape if I see them on a student's desk. I throw them away without reading them when they end up on the floor.
But...
I do take care of business when
* the student is disrupting the class by passing the note
* the student is not taking class notes but writing a personal note
* the student writes horrible things about another and reads it aloud -- yes, this happened in a class
So, I am betting that most of you have your note passing stories. I just think in the schools today where students worry about drug dogs in the halls, bullies in the lunch room and gangs on the corner that note passing is not that big of a deal. You may disagree.