Safford Unified School District v. Redding
Following is the case brief for Safford Unified School District v. Redding, 557 U.S. 364 (2009)
Case Summary of Safford Unified School District v. Redding:
- The Safford middle school Assistant Principal suspected 13-year-old Redding of possessing pain relief pills.
- After searching her belongings, he directed two female school officials to strip search Redding. The search yielded no pills.
- Redding’s family sued the school and the school officials individually in federal court.
- The District Court granted summary judgment to the school and school officials.
- The Ninth Circuit reversed.
- The U.S. Supreme Court held that the strip search violated Redding’s Fourth Amendment rights, but that the school officials were protected from suit by qualified immunity.
Safford Unified School District v. Redding Case Brief
Statement of the Facts:
Based on a student tip, the Assistant Principal of Safford’s middle school suspected 13-year-old Savanna Redding of possessing prescription-strength and over-the-counter pain relief pills, which was against school policy. After failing to find any pills in Redding’s belongings, the Assistant Principal directed two female school officials to strip search Redding. No pills were found in that search.
Redding’s family filed a federal lawsuit against the Safford school district and against the school officials individually, claiming that the strip search violated Redding’s Fourth Amendment rights.
- The District Court granted summary judgment in favor of the school and school officials.
- The Ninth Circuit Court of Appeals reversed, holding that the strip search violated the Fourth Amendment, and that the Assistant Principal was not protected from suit by qualified immunity, though the other school officials were.
- The U.S. Supreme Court granted certiorari.
Issues and Holdings:
- Did the strip search of a student suspected of possessing drugs against school policy violate the Fourth Amendment? Yes.
- Are the school officials involved in the search individually liable for their actions in this case? No.
The decision of the Ninth Circuit Court of Appeals is affirmed in part, reversed in part, and remanded.
Rule of Law or Legal Principles Applied:
- A school search is permissible when the measures used are reasonably related to the reason for the search, and not excessively intrusive under the circumstances.
- Because the law was not clear as to whether a school strip search violated the Fourth Amendment, the school officials have qualified immunity from suit.
The Fourth Amendment in the school setting is based on reasonableness, and probable cause is not necessary. Yet, the manner of the search must be appropriate to the circumstances.
Given the information available to the Assistant Principal, he had enough suspicion to search Redding’s backpack and outer clothing, but there was no information that would justify a strip search in this case. There was no information indicating that Redding had pills on her person that day or would carry them in her underwear, or that the pills posed a danger to the school. Thus, the intrusiveness of the search went far beyond what was justified here, and therefore the school violated Redding’s Fourth Amendment rights.
Even though the strip search violated Redding’s Fourth Amendment rights, the school officials, including the Assistant Principal who directed the search, cannot be held personally liable. Because the law regarding school strip searches is unclear, the officials are entitled to qualified immunity.
The case must be remanded to address the issue of the school district’s liability in this matter.
Concurring and Dissenting Opinions:
Concurring in part, Dissenting in part (Stevens):
This is a case where clearly established law meets clearly outrageous conduct. It does not take a constitutional scholar to conclude that a strip search of a 13-year-old child might invade the child’s constitutional rights. Therefore, the Assistant Principal who authorized the search should not be given qualified immunity.
Concurring in part, Dissenting in part (Ginsburg):
The Assistant Principal abused his authority in this case, and it was not reasonable for him to believe that the law permitted the search he ordered. He should not be entitled to the defense of qualified immunity.
Concurring in part, Dissenting in part (Thomas):
The school officials should have qualified immunity, and the search of Redding did not violate the Fourth Amendment. School officials should have broad authority to closely supervise and protect children. Because the search was in a location where pills could have been hidden, the search was reasonable.
Safford Unified School District v. Redding is important because it gives further Fourth Amendment protections to school students, in finding that a strip search of a middle school student is not justified unless school officials have reason to believe the suspected drugs posed a danger to the school, or are hidden in the student’s underwear.