Vernonia School District 47J v. Acton
Following is the case brief for Vernonia School District 47J v. Acton, 515 U.S. 646 (1995)
Case Summary of Vernonia School District 47J v. Acton:
- Finding that the drug problem in the school district was getting alarmingly worse, and that school athletes were leaders in the drug culture at school, the Vernonia School District 47J created a student-athlete drug policy.
- The drug policy allowed for random urinalysis screening for all students who participate in school athletic programs.
- Respondent Acton refused to consent to the student-athlete drug policy and, therefore, was not allowed to participate in school athletics.
- Acton and his parents sued in federal district court, seeking a declaration that the drug policy violated the Fourth and Fourteenth Amendments, and the Oregon Constitution.
- The district court denied the suit, but the Ninth Circuit Court of Appeals reversed.
- The U.S. Supreme Court reversed the Ninth Circuit, holding that the drug policy did not violate the Fourth Amendment’s prohibition against unreasonable searches and seizures.
Vernonia School District 47J v. Acton Case Brief
Statement of the Facts:
The Vernonia School District in Oregon noted a precipitous rise in drug and alcohol abuse at school. After trying a number of informational and disciplinary efforts to curb the student drug problem, the school district ultimately created the Student Athlete Drug Policy.
The school district invited input from the district’s parents in formulating the policy. The drug policy allowed for random urinalysis screening for all students in the district who participated, or wished to participate, in the school’s athletic programs.
Seventh-grader James Acton, signed up to play football in the district. However, he and his parents refused to sign a consent allowing for Acton to be tested under the drug policy. As a result, Acton was not allowed to play football. Acton and his parents sued in federal district court, claiming that the drug policy was an unreasonable search and seizure in violation of the Fourth Amendment, the Fourteenth Amendment, and the Oregon Constitution. They sought declaratory relief, and an injunction, putting a halt to the drug policy.
- The federal district court denied Acton’s claims.
- The Ninth Circuit Court of Appeals reversed, finding that the drug policy violated both the federal and State constitutions.
- The U.S. Supreme Court granted certiorari.
Issue and Holding:
Does a school policy allowing for random drug screening of student athletes constitute an unreasonable search and seizure under the Fourth Amendment? No.
The decision of the Ninth Circuit Court of Appeals is reversed and remanded.
Rule of Law or Legal Principle Applied:
A public school policy of randomly drug testing student athletes in the face of a school-wide drug problem does not constitute an unreasonable search and seizure in violation of the Fourth Amendment.
State-compelled collection and testing of a person’s urine sample is a “search” for purposes of the Fourth Amendment. The important issue here is whether the search in question – the drug policy – is reasonable. Reasonableness of a search is determined by balancing the intrusion on a person’s Fourth Amendment interests against the governmental interest that the search is promoting. In this case, the drug policy is reasonable when balancing those interests.
With regard to the student’s Fourth Amendment privacy interests:
- Students already have a diminished expectation of privacy compared to adults by virtue of the school’s supervisory authority.
- School children must also submit to physical exams and vaccinations regularly.
- Student athletes have an even lesser privacy expectation because they are subject to pre-season exams and typically share communal locker rooms.
- Further, the collection of the urine sample is not at all intrusive, given that same-sex monitors observe only to avoid sample tampering. The information gleaned from the testing of the sample is to a limited audience.
With regard to the government interest at issue:
- No one doubts the need to deter drug use by school children.
- The drug policy at issue is limited only to student athletes.
- Given the extent of the drug problem, the district court’s determination that the school district’s concerns were immediate was not clearly erroneous.
- Finally, the Fourth Amendment does not require the “least intrusive” search in all cases, thus requiring a search based on suspicion of drug use is not necessary.
When balancing the competing interests, the decreased expectation of privacy, the relative unobtrusiveness of the search, and the serious need to address the drug problem at school, lead to the conclusion that the drug policy is reasonable and constitutional under the Fourth and Fourteenth Amendments.
Concurring and Dissenting Opinions:
Concurring Opinion (Ginsberg):
The drug policy only applies to athletes, and the most severe sanction is removal from playing sports for the school. The Court’s opinion appears to, appropriately, avoid the question of whether it can impose the drug policy to all students, rather than just athletes.
Dissenting Opinion (O’Connor):
The Court’s decision allows an intrusive search of millions of student athletes across the country who have not provided any reason for school officials to suspect that they use drugs. The Court’s decision here is wrong because it allows for a blanket search of students. For most of the country’s history, mass, suspicionless searches have been deemed per se unreasonable under the Fourth Amendment. There is no evidence to show that a suspicion-based policy would be ineffectual, and therefore the blanket search policy should be considered unconstitutional.
Vernonia School District 47J v. Acton sparked some controversy. Some supporters of the “war on drugs” hailed the decision as a victory for children, while others found that the decision put children in the status of “second-class citizens.” The case demonstrates the challenges of balancing interests under the Fourth Amendment.