Veronia School District 47J v. Acton, 515 U.S. 646 (1995)

Facts

Veronia School District began to see problems with drug use in its schools and felt that athletes were among the largest users.  After a parent meeting, the District implemented a drug testing policy for all student athletes, which required a test at the beginning of the season and random tests throughout the season.  Acton and his parents refused to sign the testing consent forms.

Procedural History

The Actons filed for a declaratory judgment and an injunction, but the District Court denied the claims.  The Ninth Circuit reversed, finding the District’s policy violated the Fourth and Fourteenth Amendments.

Issue(s)

Did the Ninth Circuit err in finding that a school district’s policy of drug testing student athletes is a violation of the Fourth Amendment?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that a search unsupported by probable cause can be constitutional when special needs make the warrant and probable cause requirements impractical.  These special needs have been found to exist in the public-school context.  Fourth Amendment rights are different in public schools; the reasonableness inquiry cannot disregard the school’s custodial and tutelary responsibility for children.  Legitimate privacy expectations are even less with regard to student athletes.  When looking at all of the factors – decreased expectation of privacy, relative unobtrusiveness of the search, and the severity of the need met by the search – we conclude Veronia’s policy is reasonable and hence constitutional.

Judgment/Outcome

The Court reversed and remanded the judgment of the Ninth Circuit.