New Jersey v. T.L.O.

Supreme Court of United States
469 U.S. 325 (1985)

ELI5:

Rule of Law:

The Fourth Amendment's prohibition on unreasonable searches and seizures applies to public school officials, but they may search a student's belongings without a warrant if they have a reasonable suspicion that the student has violated or is violating either the law or a school rule.

Facts:

A teacher at Piscataway High School discovered T.L.O., a 14-year-old freshman, and another girl smoking cigarettes in a school lavatory in violation of school rules.
The teacher escorted the two students to the Assistant Vice Principal's office.
When questioned by Assistant Vice Principal Theodore Choplick, T.L.O.'s companion admitted to smoking, but T.L.O. denied smoking in the lavatory and claimed she did not smoke at all.
Choplick demanded to see T.L.O.'s purse. Upon opening it, he found a pack of cigarettes.
As he removed the cigarettes, Choplick noticed a package of cigarette rolling papers, which, in his experience, was associated with marijuana use.
Suspecting drug involvement, Choplick proceeded to search the purse more thoroughly.
The thorough search revealed a small amount of marihuana, a pipe, empty plastic bags, a significant amount of cash in one-dollar bills, and an index card listing students who owed T.L.O. money.
Choplick turned the evidence of drug dealing over to the police, and T.L.O. subsequently confessed to selling marihuana at the school.

Procedural Posture:

The State of New Jersey brought delinquency charges against T.L.O. in the Juvenile and Domestic Relations Court of Middlesex County.
At trial, T.L.O.'s counsel filed a motion to suppress the evidence found in her purse, arguing the search violated the Fourth Amendment.
The Juvenile Court (the trial court) denied the motion to suppress, found T.L.O. to be a delinquent, and sentenced her to one year of probation.
T.L.O. appealed to the New Jersey Appellate Division (an intermediate appellate court), which affirmed the trial court's finding that the search was constitutional.
T.L.O. then appealed to the Supreme Court of New Jersey (the state's highest court), which reversed the lower courts, holding that the search was unreasonable and ordering the suppression of the evidence.
The State of New Jersey, as petitioner, successfully petitioned the U.S. Supreme Court for a writ of certiorari to review the decision of the New Jersey Supreme Court.

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Issue:

Does a warrantless search of a student's purse by a public school official, based on a reasonable suspicion that the student has violated a school rule, violate the Fourth Amendment's prohibition against unreasonable searches and seizures?

Opinions:

Majority - Justice White

No. The search of T.L.O.'s purse did not violate the Fourth Amendment. The court established that while the Fourth Amendment applies to school officials, the school environment requires an easing of the restrictions typically imposed on public authorities. The legality of a search should depend on its reasonableness under all circumstances, which involves a two-part inquiry: 1) whether the action was justified at its inception, and 2) whether the search as conducted was reasonably related in scope to the circumstances which justified the interference. A search is justified at its inception when there are reasonable grounds for suspecting it will uncover evidence of a violation of law or school rules. In this case, the teacher's report of T.L.O. smoking provided a reasonable suspicion to justify the initial search of her purse for cigarettes. The subsequent discovery of rolling papers then gave rise to a reasonable suspicion of marihuana possession, justifying the further, more thorough search of the purse.

Concurring - Justice Powell

No. I agree with the Court's holding but would place greater emphasis on the special characteristics of the school environment. Students within the school environment have a lesser expectation of privacy than the general population. The Court must balance the student's legitimate privacy interests against the school's need to maintain discipline, which is essential for education. The commonality of interests between teachers and pupils, focused on welfare and education, distinguishes this relationship from the adversarial one between law enforcement and criminal suspects.

Concurring - Justice Blackmun

No. I agree with the judgment but write to emphasize that departing from the probable-cause requirement is only permissible in exceptional circumstances with special needs beyond normal law enforcement. The school setting presents such a special need for flexibility to maintain safety and a conducive learning environment, which makes the warrant and probable-cause requirement impracticable. A teacher is not a law enforcement officer and should not be burdened with the complexities of probable cause when immediate action is necessary to maintain order or safety.

Dissenting - Justice Brennan

Yes. The search of T.L.O.'s purse violated her Fourth Amendment rights. The majority's 'reasonableness' standard is an unprecedented and unnecessary departure from the probable-cause requirement, which is the constitutional minimum for a full-scale search. The presence of cigarette rolling papers, a common and legal item, was insufficient to establish probable cause to believe T.L.O. possessed marihuana. By discarding the probable cause standard, the Court's balancing test weakens Fourth Amendment protections for all citizens and gives school officials unchecked discretion.

Dissenting - Justice Stevens

Yes. The search of T.L.O.'s purse was unreasonable and thus violated the Fourth Amendment. The Court's new standard is too broad because it permits searches for violations of even the most trivial school rules. The reasonableness of a search should depend on the gravity of the suspected offense. Here, the suspected infraction—smoking in a lavatory—was a minor violation that did not pose a serious threat to school discipline or safety, and therefore did not justify the significant invasion of privacy involved in searching a student's purse. The initial search was not justified at its inception.

Analysis:

This landmark decision established the 'reasonable suspicion' standard for searches conducted by public school officials, creating a significant exception to the Fourth Amendment's probable cause requirement. The Court's balancing test gives substantial weight to the unique needs of the school environment in maintaining order and safety, thereby affording students a lesser expectation of privacy at school compared to adults in other settings. This precedent grants school administrators considerable latitude to conduct searches and has become the foundational framework for analyzing the constitutionality of student searches in public schools, influencing policies and legal challenges nationwide.

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