T.L.O. was a 14-year-old female student at a New Jersey high school. A teacher found T.L.O. and another student smoking cigarettes in the girls’ bathroom at school. A school administrator questioned T.L.O. and she denied the accusation. The administrator accused T.LO. of lying to him. He searched T.L.O.’s purse and found a pack of cigarettes, cigarette rolling paper, a small plastic bag containing a grass-like substance, and a letter that appeared to implicate T.L.O. in dealing marijuana. The administrator contacted the police. Her mother brought T.L.O. to the police station, where she confessed to selling marijuana.
The Juvenile Court denied T.L.O.’s motion to suppress her confession and the evidence from the search. Her lawyer argued that the search of her purse was a violation of the Fourth Amendment. T.L.O. was found delinquent and was put on probation for one year. After a lengthy appeal process in the New Jersey state court system, the U.S. Supreme Court of the United States agreed to hear the case.
Issue before the Supreme Court of the United States: Whether evidence unlawfully seized by a school official – without involvement of law enforcement officials – should be allowed as evidence at juvenile delinquency proceedings.
U.S. Supreme Court Ruling: The Court concluded that, under the circumstances of this case, the search of T.L.O.’s purse did not violate the Fourth Amendment. The Court did not address the issue of whether unlawfully seized evidence should be suppressed in a juvenile delinquency hearing. However, the Court decided that the Fourth Amendment applies to school officials.
Reasoning: 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. It also applies to the conduct of public school officials. Public school teachers act as agents of the state. Thus, the Fourth Amendment applies to their actions.
The Court also held that students have some legitimate expectation of privacy at school. However, the students’ expectation of privacy must be balanced against the needs of school authorities to maintain an educational environment.
Source: New Jersey v. TLO (1985) #1
Administrative Office of the U.S. Courts