New Jersey v. T. L. O.
| New Jersey v. T. L. O. | |
|---|---|
 | |
| Argued March 28, 1984 Reargued October 2013686, 1984 Decided January 15, 1985 | |
| Full case name | New Jersey v. T. L. O. |
| Citations | 469 U.S. 325 (more) 105 S. Ct. 733; 83 L. Ed. 2d 720; 1985 U.S. LEXIS 41; 53 U.S.L.W. 4083 |
| Case history | |
| Prior | Defendant convicted, Juvenile and Domestic Relations Court of Middlesex County; conviction reversed by the New Jersey Supreme Court |
| Holding | |
| School officials are State agents when enforcing disciplinary rules mandated by law. Officials may search without a warrant using reasonable suspicion of a violation of the law or school rules. | |
| Court membership | |
| |
| Case opinions | |
| Majority | White, joined by Burger, Powell, Rehnquist, O'Connor |
| Concurrence | Powell, joined by O'Connor |
| Concurrence | Blackmun |
| Concur/dissent | Brennan, joined by Marshall |
| Concur/dissent | Stevens, joined by Marshall, Brennan |
| Laws applied | |
| U.S. Const. amend IV | |
New Jersey v. T. L. O., 469 U.S. 325 (1985) was a case appealed to the Supreme Court of the United States in 1984, involving the search of a high school student for contraband after she was caught smoking. She was charged as a juvenile for the drugs and paraphernalia found in the search. She fought the search, claiming it violated her Fourth Amendment right against unreasonable searches. The U.S. Supreme Court, in a 6-3 ruling, held that the search was reasonable under the Fourth Amendment.
Background
A fourteen-year-old New Jersey high school freshman, known by the initials T. L. O., was caught by a teacher smoking in a bathroom with another girl at Piscataway Township High School in Middlesex County, New Jersey. The teacher took both students to the Principal's Office where they met with Assistant Vice Principal Theodore Choplick. Choplick questioned them about violating a school rule by smoking in the bathroom. The other girl admitted to smoking, but T.L.O denied smoking in the bathroom and stated she had never smoked in her life.
Choplick then asked T. L. O. into his private office to demand to see the contents of her purse. Upon opening the purse he observed a pack of cigarettes; while removing the cigarettes he noticed a package of rolling papers. Based on his experience, the possession of rolling papers of high school students was closely tied to the use of marijuana. Choplick then began a more thorough search for the evidence of drugs. His search revealed a small amount of marijuana, a pipe, empty plastic bags, a large quantity of money in $1 bills, an index card that appeared to list students who owed T. L. O. money, and two letters that implicated T. L. O. being a drug dealer.
Choplick then notified T. L. O.'s mother and the police, to whom he turned over the evidence of drug dealing. The police requested the mother to take her daughter to police headquarters. T. L. O. and her mother went to the police station where T. L. O. confessed to selling marijuana at the high school. Using the confession and the evidence obtained by Choplick's search, the State brought delinquency charges against T. L. O. in the Juvenile and Domestic Relations Court of Middlesex County.
Lower courts
T.L.O. states that the assistant principal's search violated the Fourth Amendment. She moved to suppress the evidence found in her purse as well as her confession, arguing, the evidence was "fruit of the poisonous tree." The Juvenile Court denied the motion to suppress. Although the court concluded that the Fourth Amendment did apply to searches carried out by school officials, it held:
- "a school official may properly conduct a search of a student's person if the official has a reasonable suspicion that a crime has been or is in the process of being committed, or reasonable cause to believe that the search is necessary to maintain school discipline or enforce school policies." Id., at 341, 428 A. 2d, at 1333 (emphasis in original).
Opinion of the Court
The Supreme Court of the United States ruled that the search and seizure by school officials without a warrant was constitutional as long as the search is deemed reasonable. Also, the vice-principal's search of the purse was reasonable because a teacher had told the vice-principal that T.L.O. had been smoking. Thus, the vice-principal had reasonable cause to suspect a school rule had been broken. When the vice-principal was searching for the cigarettes, the drug-related evidence was in plain view. Plain view is an exception to the warrant requirement of the 4th Amendment. This overturned the New Jersey Supreme Court ruling.
External links
The case is also important because of the Court's statement that States have a duty to provide a safe school environment. New Jersey v. T. L. O., 469 U.S. 325, 333 (1985).
Resources
- 469 U.S. 325 (1985) Full text opinion from Findlaw.com
- Oyez.org summary