Board of Education v. Earls

Following is the case brief for Board of Education v. Earls, 536 U.S. 822 (2002)

Case Summary of Board of Education v. Earls:

  • The Tecumseh, Oklahoma, School District has a policy of drug testing all middle and high school students who participate in extracurricular activities.
  • Several students and their families sued, claiming that the policy violates their civil rights and the Fourth Amendment.
  • The district court upheld the policy.  The Tenth Circuit, however, found the policy in violation of the Fourth Amendment because there was no schoolwide drug problem sufficient to justify suspicionless searches.
  • The U.S. Supreme Court reversed the Tenth Circuit, holding that there is no violation of the Fourth Amendment because the policy is a reasonable way to address the school’s important interest in keeping drugs out of the hands of students.

Board of Education v. Earls Case Brief

Statement of the Facts:

The Tecumseh, Oklahoma, School District has a Student Activities Drug Testing Policy that requires all middle and high school students to consent to urine drug tests in order to participate in any extracurricular activity.  In reality, the policy was only applied to competitive extracurricular activity participants.

Several high school students and their parents sued, claiming a violation of civil rights and of the Fourth Amendment.

Procedural History:

  • The District Court granted summary judgment in favor of the school’s policy based on Vernonia School Dist. 47J v. Acton.
  • The Tenth Circuit reversed, finding the policy in violation of the Fourth Amendment because there was no factual basis showing a drug problem to justify suspicionless searches.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Does a drug test requirement for every middle and high school student involved in extracurricular activities violate the Fourth Amendment?  No.

Judgment:

The decision of the Tenth Circuit Court of Appeals is reversed.

Rule of Law or Legal Principle Applied:

Suspicionless drug testing of all middle and high school students involved in extracurricular activities does not violate the Fourth Amendment.

Reasoning:

The Student Activities Drug Testing Policy reasonably serves the School District’s important interest in detecting and preventing drug use in students.  Therefore, the policy is constitutional.  The policy diminishes the student’s expectation of privacy at the front end when a student chooses to engage in extracurricular activities.  Also, the actual test itself is minimally intrusive.  The Court does not comment on the wisdom of the drug policy, just that it is a reasonable way to achieve the School District’s interest in deterring drug use in the schools.

Concurring and Dissenting Opinions:

Concurring Opinion (Breyer):

The drug problem in this country justifies the school policy.  The attempts to stop the supply of drugs has not reduced drug use in teenagers, and schools need a way to address the problem.  The Constitution does not prohibit the school’s reasonable effort here.

Dissenting Opinion (O’Connor):

The Court’s decision was decision was wrong in Vernonia and it is wrong here as well.

Dissenting Opinion (Ginsburg):

The policy upheld in this case is “not reasonable; it is capricious, even perverse:  Petitioners’ policy targets for testing a student population least likely to be at risk from illicit drugs and their damaging effects.”

Significance:

Board of Education v. Earls is a significant decision because it expands the drug policy allowed in Vernonia to a mandatory drug testing policy without any suspicion of wrongdoing.

Student Resources:

Read the Full Court Opinion

Listen to the Oral Arguments

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