Facts of the Case

In 1980, a teacher at Piscataway High School in New Jersey discovered two girls smoking in the school restroom, which was a violation of school rules. One of the students, identified as T.L.O. (a juvenile), denied smoking. The assistant vice principal searched T.L.O.’s purse and found cigarettes. While searching further, he discovered rolling papers, marijuana, a pipe, empty plastic bags, a large amount of cash, and a list of students who owed her money. T.L.O. was charged with delinquency for dealing drugs.

T.L.O. moved to suppress the evidence found in her purse, arguing that the search violated her Fourth Amendment right against unreasonable searches and seizures. The New Jersey courts were split on the issue, with the New Jersey Supreme Court ruling in T.L.O.’s favor, stating that the search was unreasonable.

Constitutional Question

Does the Fourth Amendment’s prohibition on unreasonable searches and seizures apply to searches conducted by public school officials, and, if so, under what circumstances can school officials conduct a search of a student’s property?

Arguments

For T.L.O. (the defense):

• T.L.O.’s defense argued that the assistant principal’s search violated her Fourth Amendment rights because it was conducted without a warrant and lacked probable cause.
• The defense contended that students, like adults, are entitled to full constitutional protections against unreasonable searches and seizures, and the evidence obtained in the unlawful search should be suppressed.

For New Jersey (the state):

• The state argued that while students do have Fourth Amendment protections, the unique environment of public schools requires school officials to have more leeway in maintaining order and discipline.
• The state contended that school officials should not be required to meet the same standard of probable cause as law enforcement officers when conducting searches, and that reasonable suspicion should be sufficient in the school setting.

The Decision

The Supreme Court, in a 6-3 decision, ruled in favor of the State of New Jersey. Justice Byron White, writing for the majority, held that the Fourth Amendment applies to searches conducted by public school officials, but that school officials do not need to adhere to the same probable cause standard required of law enforcement. Instead, school officials only need to meet the lower standard of “reasonable suspicion” to justify a search.

The Court reasoned that public schools are a unique environment where officials must maintain order and ensure the safety of students. Therefore, requiring a warrant or probable cause would unduly interfere with school officials’ ability to maintain a safe and disciplined environment. The search of T.L.O.’s purse was deemed reasonable because the discovery of cigarettes gave the assistant principal reasonable suspicion to believe she was violating school rules.

Significance

New Jersey v. T.L.O. is a landmark case that defined the extent of Fourth Amendment protections for students in public schools. The ruling established the “reasonable suspicion” standard for searches conducted by school officials, providing them with greater flexibility to maintain school safety and discipline. This case has had a profound impact on how schools across the United States approach searches of students and their belongings, balancing students’ rights with the need for a secure educational environment.

The decision also reinforced the idea that students do not shed their constitutional rights at the schoolhouse gate, but those rights can be adjusted to fit the special needs of the school environment. Since this ruling, courts have further clarified the limits of school searches, and the “reasonable suspicion” standard remains the guiding principle in student search cases.