in a lie did not justify rummaging through her purse. Since TLO did have cigarettes in her possession and was caught in the restroom and taken directly to the office; the vice principal had a reasonable cause to suspect a search. However, the Court held students have less of an expectation of privacy at school than in other places. Because of this, the state has … The first case to use this doctrine was the 1914 decision Weeks v. United States. The majority opinion, delivered by Justice White, stated that the school's search was reasonable and decided that in a school setting no warrant or probable cause is necessary because privacy expectations are lower when at school. The opinion of the court was in favor of the State of New Jersey, by a 6-3 vote. Justice Stevens would have held the exclusionary rule applied to school searches and left it at that. As such, school authorities do not need to obtain a warrant or have probable cause that a crime occurred before searching a student. Many of the Supreme Court's most notable cases involve the constitutional rights of students in public schools. However, he added a section on the majority's decision, writing that students have the same expectation of privacy for their personal belongings that anyone else has. Among other things, when the administrator opened her purse, he found a pack of cigarettes, and cigarette rolling paper. 2d 720 (1985) Brief Fact Summary. That was TLO's argument, New Jersey's argument was simply marijuana is illegal and so is smoking under age, especially on school grounds. What was clear after New Jersey v. The court sided with the school, and T.L.O. Fourth Amendment law can be extremely complex, and exceptions and gray areas exist, but essentially police cannot search a person without probable cause. 's purse. Begin typing to search, use arrow keys to navigate, use enter to select. Justice Stevens, in his concurrence in part and dissent in part, noted that the Court should address the original issue, i.e., whether the exclusionary rule applies to searches made by public school officials and teachers in school. This question lingers in various forms to this day. 's purse. 's case. According to Justice White, who wrote the majority opinion, ". Internet Explorer 11 is no longer supported. The New Jersey court did not hold that the school's smoking rules were unrelated to the goal of maintaining discipline or order, nor did it suggest that a search that would produce evidence bearing directly on an accusation that a student had violated the smoking rules would be impermissible under the court's reasonable-suspicion standard; rather, the court concluded that any evidence a search of T.L.O… For instance, in Mapp v. Ohio, 367 U.S. 643 (1961), the Court held that the Fourth Amendment’s prohibition on unreasonable searches and seizures was applicable to States. However, they wrote separately to emphasize that students have less of a privacy expectation in school than others. A teacher found T.L.O. Do students have Fourth Amendment protections against unreasonable searches and seizures by teachers and school staff? Ultimately, T.L.O. Dunaway v. New York, 442 U.S. 200, 210 (1979); Terry v. Ohio, supra. Again, this is a complicated area of the law, but these are the basics of search and seizure law. had been smoking in violation of school rules constituted reasonable suspicion that cigarettes were in her purse (a fact that would be relevant to the smoking accusation). Reviewed by Laura Temme, Esq. The underlying circumstances surrounding New Jersey v. T.L.O. are not particularly unusual. T.L.O. T.L.O. Lower Court 1:  Juvenile and Domestic Relations Court of Middlesex County, N.J. Lower Court 1 Ruling: The Fourth Amendment applies to searches carried out by school officials, but a school official may conduct a search of a student’s person under certain circumstances. Specifically, the Juvenile Court held that a school official may search a student if the official has reasonable suspicion that a crime has been or is in the process of being committed, or has reasonable cause to believe the search is necessary to maintain school discipline or enforce polices. New Jersey v. The vice principal found marijuana papers alongside a pack of cigarettes, which led to a more thorough search of T.L.O. The second student admitted to smoking cigarettes. A teacher found T.L.O. Citation469 U.S. 325, 105 S. Ct. 733, 83 L. Ed. Under this Supreme Court doctrine, evidence found in violation of a person's Fourth Amendment right is not admissible in court. In other words, Justice Stevens also disagreed with the majority's newly created standard for the lawfulness of school searches. If a criminal defendant can successfully argue that officers did not have probable cause to conduct a search, then the case against the defendant usually falls apart. Lower Court 3:  New Jersey State Supreme Court. took her case to the New Jersey Supreme Court, which later found that the search was unreasonable and the evidence could not be used. The states are free to interpret their Constitutions and laws in a manner that gives more protections to individuals than the U.S. Constitution. Synopsis of Rule of Law. Whether evidence unlawfully seized by a school official – without involvement of law enforcement officials – should be allowed in as evidence at juvenile delinquency proceedings. The court sided with the school, and T.L.O. T.L.O. Synopsis of Rule of Law. The administrator’s desire to catch T.L.O. Public school teachers act as agents of the state, and not merely agents of the students’ parents. He further searched T.L.O.’s purse, and found a small plastic bag containing a grass-like substance and  items that could be drug paraphernalia, including a pipe, a wad of money, a piece of paper with the names of students who apparently owed T.L.O. In holding the school to the higher and more established probable cause standard, Justices Brennan and Marshall would have upheld the New Jersey Supreme Court's decision finding that the school violated T.L.O. The search is appropriate in scope if it is not "excessively intrusive" considering the student's age and the rule or law the school believes the student has violated. In several cases, the U.S. Supreme Court has incorporated various provisions of the Fourth Amendment, and related judicial rulings, to the states. The Court also held that students have some legitimate expectation of privacy at school. This is similar, but not identical, to the standard the law places on police searches. This activity is not meant to provide a legal analysis of this case or any related matters. was found delinquent, and was put on probation for one year. (1985). As noted above, this question is particularly relevant today, when students carry around significant amounts of personal information in their pocket in the form of smartphones. The provisions of the first Ten Amendments to the Constitution, i.e., the Bill of Rights (1791), originally were applicable only to the federal government, and not to state governments. The two girls were taken to the principal's office where T.L.O. - Do Students Have The Same Right To Protection Against … This body of law is still being developed. is important because it delineates a departure from standard Fourth Amendment search and seizure jurisprudence. T.L.O. Do students have Fourth Amendment protections against unreasonable searches and seizures by teachers and school staff? Justice Powell, with Justice O'Connor, agreed with the majority opinion. was charged with possession of marijuana. Disclaimer (Please Note):  This activity is meant to help high school students understand, as part of their civics education, the key facts and holdings of a well-known U.S. Supreme Court case. Stay up-to-date with FindLaw's newsletter for legal professionals, The Fourth Amendment applies to students in a public school, The Fourth Amendment prohibits unreasonable searches by teachers, as well as law enforcement officers, Students have a legitimate expectation of privacy in school, The vice principal's search of T.L.O. In a juvenile court, T.L.O. Lower Court 3 Ruling:  Agreed with the lower courts that the Fourth Amendment is applicable to the conduct of school officials; also agreed that school officials may conduct a warrantless search of a student when they have reasonable grounds to believe that a student possesses evidence of illegal activity or activity that interferes with school discipline and order. of lying to him, and demanded to see her purse in an attempt to find the cigarettes. The Court held that the Fourth Amendment’s prohibition on unreasonable searches and seizures is not limited solely to the actions of law enforcement personnel. 's companion admitted that she had been smoking in the restroom. The Court did not address the issue of whether unlawfully seized evidence should be suppressed in a juvenile delinquency hearing. Similarly, law enforcement officers can search private spaces, such as homes, if they obtain a warrant after showing to a judge they reasonably expect to find specific items connected with a crime, or if one of the exceptions such as the "plain sight" doctrine applies. Namely, the exclusionary rule and probable cause. Since these items indicated the student was selling marijuana to classmates, the school contacted the police. Google Chrome, Facts and case summary for New Jersey v. T.L.O. the court sided with the school,and T.L.O. The Court unanimously held that students have a Fourth Amendment right against unreasonable search and seizure while in school. It also applies to the conduct of public school officials. They also cannot search a place where a person would have a reasonable expectation of privacy without probable cause or first obtaining a search warrant from a court. However, the students’ expectation of privacy must be balanced against the needs of school authorities to maintain an educational environment. Learn what a scholar says about the landmark Supreme Court case New Jersey v. T.L.O. In a concurrence, Justice Blackmun agreed with the majority. In a 6-3 decision, New Jersey won the case. If, however, the state can show probable cause, then the evidence is admissible, and the defendant may have a hard time defending their case. T.L.O. 's purse was unreasonable, The search is "justified at its inception" and, The search is "reasonably related in scope to the circumstances which justified the interference in the first place". A Bankruptcy Judge? Lv 7. and another student smoking cigarettes in the girls’ restroom in the school building in violation of school rules. It says, in relevant part, “[N]or shall any state deprive any person of life, liberty, or property, without due process of law.” In a series of cases starting in 1925, the U.S. Supreme Court interpreted the 14th Amendment as “incorporating” (applying) most but not all of the provisions of the Bill of Rights to the states. . Learn more about FindLaw’s newsletters, including our terms of use and privacy policy. moved to suppress evidence discovered in the search, but the Court denied her motion. In sum, the “reasonableness” standard in T.L.O., without the need for probable cause, is a lower standard that makes students more … The vice-principal of a school searched a students bag and found evidence that she was dealing marijuana. − Respondent: The person/organization/company who won in the lower court and now argues that the lower court decision was correct. At the police station, TLO told officials that she had been selling marijuana at school. Firefox, or Many of the Supreme Court's most notable cases involve the constitutional rights of students in public schools. In 1980, a teacher at Piscataway High School in Middlesex County, New Jersey, found T.L.O. All rights reserved. Start studying New Jersey v TLO. As explained in the reasoning section below, the Court concluded that, under the circumstances of this case, the search of T.L.O.’s purse did not violate the Fourth Amendment to the U.S. Constitution. As a result of the decision, school searches of students are very fact-dependent. Justice Stevens also wrote a dissenting opinion, joined by Justice Marshall and in part by Justice Brennan, holding that the Supreme Court should have limited its decision to whether the exclusionary rule applied in this case. First case to use this doctrine was the reason the Supreme Court, which later that. Court decision, Justice Stevens, with Justice O'Connor, agreed with the school in... 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