New Jersey v. T.L.O., 1985

Supreme Court: SOMETIMES


T.L.O. was a 14-year-old female student at a New Jersey high school. A teacher found T.L.O. and another student smoking cigarettes in the girls’ restroom in the school building in violation of school rules. The teacher brought the two students to a school administrator, who questioned each of them. The second student admitted to smoking cigarettes. T.L.O. denied the allegations. The administrator then accused T.L.O. of lying to him, and demanded to see her purse in an attempt to find the cigarettes. Among other things, when the administrator opened her purse, he found a pack of cigarettes, and cigarette rolling paper. Due to the face that the administrator knew that cigarette rolling paper is used to smoke marijuana he now suspected T.L.O. of marijuana use. He further searched T.L.O.’s purse, and found a small plastic bag containing a grass-like substance and items that could be drug paraphernalia, including a pipe, a wad of money, a piece of paper with the names of students who apparently owed T.L.O. money, and a letter that appeared to implicate T.L.O. in dealing marijuana. The administrator contacted the police who, in turn, contacted T.L.O.’s mother. Her mother brought T.L.O. to the police station, where she confessed to selling marijuana.

Due to her age, T.L.O. faced delinquency charges in Juvenile Court. The Juvenile Court denied T.L.O.’s motion to suppress her confession and the evidence from the search. Her lawyer argued that the search of her purse was a violation of the Fourth Amendment. T.L.O. was found delinquent, and was put on probation for one year. After a lengthy appeal process in the New Jersey state court system, the U.S. Supreme Court of the United States agreed to hear the case.

Decision and Reasoning

The Court held that the Fourth Amendment’s prohibition on unreasonable searches and seizures is not limited solely to the actions of law enforcement personnel. It also applies to the conduct of school officials. Public school teachers act as agents of the state, and not merely agents of the students’ parents. Thus, the Fourth Amendment applies to their actions.

The Court also held that students have some legitimate expectation of privacy at school. However, the students’ expectation of privacy must be balanced against the needs of school authorities to maintain an educational environment. As such, school authorities do not need to obtain a warrant or have probably cause that a crime occurred before searching a student. Rather, the reasonableness of a search, under all circumstances, will determine its legality.

The Court established the following test to determine the reasonableness of a search: whether the search was 1) justified at its inception and 2) as the search was conducted, was it reasonably related in scope to the circumstances that justified the interference in the first place.

Finally, the Court evaluated the facts of T.L.O.’s search in light of this test. First, the Court concluded that the search was justified at its inception. The initial report from the teacher that T.L.O. had been smoking in violation of school rules constituted reasonable suspicion that cigarettes were in her purse. Second, the Court noted that the discovery of rolling paper provided reasonable suspicion that T.L.O. possessed marijuana, and this justified the further search of her purse. Since the school administrator’s actions were justified at the inception and were reasonably related in scope to the circumstances that justified the interference, the search was reasonable. Although the Court held that the Fourth Amendment applied to the school administrator’s actions, the Court ultimately determined that his actions in this case did not violate the Fourth Amendment.

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