(Simple case brief)

SAFFORD SCHOOLS V. REDDING (2009) U.S. Supreme Court

“Score” 8-1

Majority opinion author:  Justice David Souter

Facts:  A middle school student reported that fellow student Marissa Glines was giving prescription strength Ibuprofen to other students.  The day planner carried by Glines was found to contain pills.  Glines denied any knowledge of the pills and said she was given the dayplanner by Savana Redding.  Redding also denied knowledge of the pills.  School officials searched Reddings’ belongings and then ordered Redding to disrobe and shake out her underwear in front of school officials.  No pills were found in her possession.  Her family sued the school officials over the intrusive search.

Issue:  Did school officials violate teenage student Redding’s Fourth Amendment right against “unreasonable searches” by requiring the student to disrobe and shake out her underwear in front of school officials based solely on a report from another student that Redding possessed and distributed the prescription-strength version of over-the-counter pain pills?

Holding:  Yes, school officials violated teenage student Redding’s Fourth Amendment right against “unreasonable searches” by requiring the student to disrobe and shake out her underwear in front of school officials based solely on a report from another student that Redding possessed and distributed the prescription-strength version of over-the-counter pain pills.

Reasoning:  Searches are reasonable under the Fourth Amendment when, after balancing the government’s interest and the individual’s privacy interest, the government interest is stronger. Redding suffered a significant intrusion based solely on a statement from another student and no specific evidence that contraband was hidden on her body.  The other student’s statement justified a search of a backpack and other belongings because of the important need to protect students from drugs, but did not provide enough justification to require disrobing and examining underwear.

Concurring opinion(s):  (Justice Clarence Thomas concurred with the part of the opinion-omitted above—that concluded school officials could not be sued for money damages due to qualified immunity).

Dissenting opinion(s):  Justice Thomas:  school officials did not violate the student’s Fourth Amendment right because they stand in the place of parents while students are at school and must protect students’ health and safety.  School officials, parents, and school board members should determine policies and practices at schools—judges should not make those decisions.