New Jersey v. T.L.O.

Following is the case brief for New Jersey v. T.L.O., 469 U.S. 325 (1985)

Case Summary of New Jersey v. T.L.O.:

  • A 14-year-old high school student, T.L.O., was found smoking in the girls’ restroom at school.  The Assistant Vice Principal subsequently searched her purse and found evidence of both cigarette smoking and marijuana dealing at the school.
  • At the juvenile proceeding, T.L.O. claimed that the search of her purse violated her Fourth Amendment rights.
  • The New Jersey Supreme Court agreed that the search was unreasonable.
  • The Supreme Court reversed.  It held that a school search is justified under the Fourth Amendment if it is reasonable to suspect that the search would yield evidence of a violation of law or school rule.

New Jersey v. T.L.O. Case Brief

Statement of the Facts:

Two girls in Piscataway High School in New Jersey were smoking in the girls’ restroom.  They were caught by a teacher, who took the girls to the Assistant Vice Principal.  One girl admitted to smoking in response to the Assistant Vice Principal’s questioning.  However, the other girl, 14-year-old T.L.O., denied she was smoking, and claimed that she did not smoke at all.

The Assistant Vice Principal then demanded to see T.L.O.’s purse.  He found a pack of cigarettes and a package of rolling paper, often used to smoke marijuana.  The Assistant Vice Principal searched further in the purse and found evidence that T.L.O. was dealing marijuana at the school.  T.L.O. was then taken to the police station where she admitted to selling marijuana at the high school.

Procedural History:

  • The State of New Jersey brought juvenile charges against T.L.O.  She moved to suppress all of the evidence, claiming the search of her purse violated the Fourth Amendment.
  • The juvenile court denied the motion to suppress and ultimately sentenced her to one-year probation.
  • The N.J. Appellate Division affirmed the lower court’s finding that there was no Fourth Amendment violation.
  • The N.J. Supreme Court agreed that a warrantless search by a school official does not violate the Fourth Amendment in general, but that the search in this case was unreasonable.
  • The Supreme Court granted certiorari.

Issues and Holdings:

  1. Does the Fourth Amendment apply to searches conducted by public school officials?  Yes.
  2. Do school officials need to adhere to the warrant and probable cause requirements of the Fourth Amendment? No.

Judgment:

The decision of the New Jersey Supreme Court is reversed.

Rule of Law or Legal Principle Applied:

In general, a school official’s search of a student is justified under the Fourth Amendment if there are reasonable grounds for suspecting the search will turn up evidence that the schoolchild has violated the law or the rules of the school.

Reasoning:

The Fourth Amendment applies to searches by public school officials.  The Fourth Amendment is not limited to the conduct of law enforcement officials.  Even though school officials have a special type of authority over schoolchildren, they are still representatives of the state.  Therefore, the Fourth Amendment applies to them.

The school’s legitimate need to maintain a healthy learning environment must be balanced against a student’s legitimate expectation of privacy.  Traditional Fourth Amendment rules should be eased to strike that balance.  The search of a student by a school official comports with the Fourth Amendment if it is reasonable under all of the circumstances of the search, and school officials do not need to obtain a warrant or have probable cause before searching.

Applying the reasonableness standard to the present case, the search of T.L.O.’s purse was reasonable.  The initial search for cigarettes was in response to a suspicion that T.L.O. was smoking.  Then, the discovery of the rolling papers justified a further search based on reasonable suspicion of marijuana activity.

Concurring and Dissenting Opinions:

Concurring Opinion (Powell):

Greater emphasis should be placed on the fact that the characteristics of the school setting make it unnecessary to give students the same constitutional protections in school that they receive outside of school.  Students in school have a lesser expectation of privacy than people in society in general.

Concurring Opinion (Blackmun):

The Court omitted a crucial step in its analysis regarding whether probable cause is necessary for a search.  The nature of the school setting presents the reason for easing the probable cause standard.

Dissenting Opinion (Brennan):

The Court has adopted an “unclear, unprecedented, and unnecessary” departure from generally applicable Fourth Amendment standards.  Thus, full-scale searches are now sanctioned under an indefinite “reasonableness” standard.  The Fourth Amendment applies to school searches, and probable cause is in the text of the Fourth Amendment.

Dissenting Opinion (Stephens):

The Court has unnecessarily reached out to decide a constitutional question.  Further, the Court’s activist opinion will result in school administrators engaging in intrusive searches based on suspicion of the most trivial of school infractions.

Significance:

New Jersey v. T.L.O. is important because it delineates a departure from standard Fourth Amendment search and seizure jurisprudence.  In sum, the “reasonableness” standard in T.L.O., without the need for probable cause, is a lower standard that makes students more susceptible to searches by school officials.

Student Resources:

Full Text – Supreme Court Opinion

Listen to Oral Arguments

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