Relevant Facts: At Township High School in New Jersey, two freshman girls were caught smoking cigarettes in the bathroom and escorted to the vice principal’s office. One of the girls, designated T.L.O. as her name was protected due to age, denied the allegations that she had been smoking. After further inquiry and directing her to his private office, the Vice Principal demanded that T.L.O. hand over her purse. Following a search, the Vice Principal discovered cigarettes. While conducting his search, however, he noticed rolling papers suitable for use with marijuana. Following a more thorough search, he uncovered a small quantity of the drug, cash, and incriminating documents tending to show that T.L.O. was in the business of dealing drugs. He contacted authorities and T.L.O. was arrested. She sought to suppress the evidence obtained from her purse at trial, and that motion was denied. Following her conviction, she appealed to the New Jersey Supreme Court, where her conviction was reversed with that court concluding that the search was unreasonable.
Issue: Do the protections of the Fourth Amendment, preventing unreasonable searches and seizures, apply to school officials? Did the search in this case violate defendant’s reasonable expectations of privacy as protected by the Fourth Amendment?
Holding: Yes, school officials act as agents of the state and are subject to the restrictions of the Fourth Amendment. No, the defendant’s rights were not violated. The search in question was based on reasonable suspicion that the defendant was in violation of a school rule, and reasonably limited to the scope of that suspicion.
Reasoning: Justice White, writing for the Court, explained that school officials are subject to the requirements of the Fourth Amendment. However, students in public school do not have the same expectations of privacy as citizens in public generally. Rather, searches are subject to a reasonableness standard rather than one of probable cause as states have a valid interest in maintaining the safety and security of school learning environments. Searches should be evaluated in light of all of the circumstances, and judged on the basis of their overall reasonableness. Ordinarily, reasonableness requires only that reasonable grounds exist under the belief the search will uncover evidence that the student is violating either the law or school rules. The nature of the search should be limited to by the nature of the infraction, the student’s age, the student’s sex, and all other factors pertaining to the search. In this case, the scope of the search was directly related to reasonable suspicion that the defendant had cigarettes in her possession in violation of school rules. Next, the discovery of rolling papers, which were in plain sight and thus also within a typical warrant exception, gave rise to the reasonable conclusion that the defendant was likely concealing marijuana, justifying the more thorough search. The discovery of additional evidence of drug possession stemmed from an initially valid search, expanded on a reasonable basis with proper suspicion, entirely consistent with the requirements of the Fourth amendment in a public school setting.
Dissent: Justice Powell, in his concurring opinion, emphasized the special nature of the schoolhouse environment and the inherently special relationship between teachers and students. The important needs of states in maintaining a thorough and efficient system of public education justifies lesser degrees of privacy for students required in order to maintain good order. Justice Blackmun also concurred in the judgment of the Court, but wrote separately to connect the schoolhouse exception to other exceptions to the warrant requirement. He reasoned that an immediate search was necessary to safeguard the safety of the school environment, judge in regard to the reasonableness of the circumstances. While he concluded by agreeing with the announced standard, he sought to emphasize the connection between the exception announced and other exceptions. Justice Brennan filed an opinion, joined by Justice Marshall, concurring in part and dissenting in part. Justice Brennan agreed that school officials were subject to the Fourth Amendment, but departed from the opinion of the Court in announcing a reasonableness standard for school searches, preferring instead to apply a traditional probable cause analysis under the Fourth Amendment. Justice Stevens also concurred in part and dissented in part, agreeing that the Fourth Amendment applied to schoolhouse searches. He argued, however, that the only question properly before the Court was whether the exclusionary rule applied to searches conducted by school officials. He contended that it did apply, and would have applied a traditional Fourth Amendment analysis on that basis while also accounting for the special circumstances of a public school- demanding heightened regard to safety and security.
Conclusion: School officials are agents of the state subject to the limitations of the Constitution. School officials, however, need not conduct searches under the same circumstances as law enforcement officers outside of the schoolhouse, and are subject to a reasonableness standard rather than one of probable cause.