New Jersey v. T.L.O
New Jersey v. T.L.O. is a landmark case that addresses the balance between students' rights and the authority of school officials to conduct searches. The case arose when a school official searched a student’s purse after discovering her smoking in the restroom. The subsequent search revealed illegal items, leading to delinquency charges against the student, T.L.O. She contested the search's legality under the Fourth Amendment, which protects against unreasonable searches and seizures. The U.S. Supreme Court ultimately ruled that school officials could conduct searches under a standard of "reasonable suspicion" rather than the stricter "probable cause" required for police officers. This ruling acknowledged that while students have a legitimate expectation of privacy, school authorities must ensure a safe and conducive learning environment. The decision set important precedents for how school officials can handle searches and emphasized the unique context of educational settings. This case remains significant in discussions about student rights and school authority in the context of legal standards.
New Jersey v. T.L.O
The Case: US Supreme Court ruling on search and seizure in public schools
Date: Decided on January 15, 1985
Significance: This decision established the standards by which the protections of the Fourth Amendment apply to searches of students by school officials.
A teacher at Piscataway High School in New Jersey found two students smoking cigarettes in a school restroom in violation of the school’s rules. After being sent to the school office, one of the students, "T.L.O.," a fourteen-year-old freshman, denied smoking. Based on the report he had received from the teacher, the assistant vice principal searched T.L.O.’s purse and discovered a pack of cigarettes. As he reached for the cigarette pack, he then noticed other items, including cigarette rolling papers, which he associated with marijuana use. He then searched the purse more thoroughly and discovered marijuana, a pipe, plastic bags, a large sum of money in single dollar bills, a list of students who owed T.L.O. money, and two letters which suggested T.L.O. was involved in marijuana sales. School officials notified T.L.O.’s mother and the police.
On the basis of this evidence and a later confession, the state brought delinquency charges against T.L.O. The student appealed the charges, arguing that because the search of her purse was improper under the Fourth Amendment the evidence was inadmissible. The US Supreme Court, however, ruled that the search was conducted within the constitutional standards of the Fourth Amendment. In its opinion, the court established standards to be used by school officials in searches of students’ pockets, purses, and other items associated with the student’s person. The court did not specifically address searches of school lockers.
Until this case, public school officials had typically relied on the doctrine of in loco parentis, whereby school officials had broad search powers akin to those of a student’s parents. The Supreme Court rejected this argument and held that when public school officials conduct a search of a student they may be held to the same Fourth Amendment standards as government officials. In its analysis, the court recognized that public school students maintain an expectation of privacy in their personal effects even on a public school campus, but did not go so far as to hold school officials to exactly the same standards as police officers in carrying out a search and seizure.
Although police officers are usually required to show they have probable cause to believe that a person has violated the law, the Supreme Court allowed that school officials may need to show only that they have a reasonable suspicion that a search would produce evidence that a student has violated a school code. The court justified this relaxed standard for school officials by citing the major social problems evident in schools nationwide and a school’s need to maintain an educational environment.
Bibliography
Bloom, Robert M. Searches, Seizures, and Warrants. Westport, Conn.: Praeger, 2003.
LaFave, W. R. Search and Seizure: A Treatise on the Fourth Amendment. 3d ed. St. Paul, Minn.: West Publishing, 1995.
McWhirter, Darien A. Search, Seizure, and Privacy. Phoenix, Ariz.: Oryx Press, 1994.
"New Jersey v. T.L.O." Legal Information Institute. Cornell University Law School, 2016. Web. 27 May 2016.
"New Jersey v. T.L.O." Oyez. Chicago-Kent College of Law at Illinois Tech, n.d. Web. 27 May 2016.
Wetterer, Charles M. The Fourth Amendment: Search and Seizure. Springfield, N.J.: Enslow, 1998.