Significance: This ruling established that searches on school grounds were not subject to strict standards of “reasonableness,” as the Constitution requires for adults. The Supreme Court abandoned its requirement that searches be conducted only when a “probable cause” exists that an individual has violated the law.
Background: T. L. O. (the initials of a 14-year-old freshman at a New Jersey high school), was caught smoking in the school bathroom and sent to the assistant vice principal. The assistant vice principal searched her purse, found cigarettes, marijuana, and marijuana-related items in it, and turned her over to the proper authorities. The juvenile court charged her as a delinquent. On appeal, the New Jersey Supreme Court reversed the decision, saying that T. L. O.’s Fourth Amendment rights against illegal search and seizure had been violated.
Decision: This case was argued on March 28, 1984; reargued on October 2, 1984; and decided on January 15, 1985, by a vote of 9 to 0. Justice Byron White spoke for the Court, with Justices Lewis Powell, Sandra Day O’Connor, and Harry Blackmun concurring. Justices William Brennan Jr., Thurgood Marshall, and John Stevens concurred in part and dissented in part. The U.S. Supreme Court reversed the decision of the New Jersey Supreme Court. The Court stated that although school officials were not immune from the restrictions of the Fourth Amendment (which outlines protections against illegal searches and seizures), they were allowed greater leeway in the application of the law. Therefore, the assistant vice principal’s search was determined to be legal.
Excerpt from the Opinion of the Court: “The legality of a search of a student should depend simply on the reasonableness, under all the circumstances, of the search. . . . Because the search resulting in the discovery of the evidence of marijuana dealing by T. L. O. was reasonable, the New Jersey Supreme Court’s decision to exclude that evidence from T. L. O.’s juvenile delinquency proceedings on Fourth Amendment grounds was erroneous [wrong].”
