The Fourth Amendment can be one of the most controversial and debatable amendments to the Constitution. Hundreds of years after its ratification, the Supreme Court is still interpreting the parameters of the amendment. The Supreme Court was yet again, faced the decision to interpret what the Fourth Amendment entailed in 1985 with New Jersey v. T.L.O. Through much debate and deliberation, the Supreme Court generated a two pronged test to determine the reasonableness of searches under the Fourth Amendment and found T.L.O. delinquent.
A female student, T.L.O., and another student were found by a teacher in the bathroom of their New Jersey public high school smoking cigarettes, which was a violation of school policies. The teacher brought the students to a school administer, where the second student admitted to smoking the cigarettes, and T.L.O did not admit to smoking the cigarettes. The administrator searched inside T.L.O’s purse and found a pack of cigarettes and cigarette rolling paper. The cigarette rolling paper suggested to the administrator that T.L.O was using the paper to smoke marijuana. Upon further search, the administrator found a grass-like substance and items such as a pipe, bundle of cash, a list of names of students who owed T.L.O money, and a letter that implied T.L.O was dealing marijuana. The administrator contacted T.L.O’s mother who brought T.L.O to the police station. T.L.O admitted to selling marijuana at the station.
T.L.O. was charged in Juvenile Court with the possession of marijuana. T.L.O. argued the search of her purse was a violation of her Fourth Amendment rights, however, the court denied T.L.O’s motions to suppress the evidence found by the administrator and her confession at the police station. T.L.O. was found delinquent and was put on probation for one year. On appeal, the Superior Court of New Jersey affirmed the Juvenile Court’s decision to deny T.O.L’s motion to suppress the evidence. Her case was then appealed to the New Jersey Supreme Court, which ruled the exclusionary rule of the Fourth Amendment does apply to public school administrators’ searches and seizures. Later, the United States Supreme Court agreed to take the case.
The issue the United States Supreme Court was facing was whether the exclusionary rule applied to public school administrators’ searches and seizures to students’ person and/or belongings.
The Supreme Court did not specifically provide an answer to the issue in question as the Court did not address the question of whether or not evidence that is seized unlawfully should be prohibited in a juvenile delinquency hearing. However, the Court did rule that the Fourth Amendment does pertain to school officials. Yet, the Supreme Court decided that under the conditions of this case, T.L.O.’s Fourth Amendment rights were not violated during the administrator’s search and seizure.
In the 6-3 vote, the Supreme Court Justices ruled that law enforcement are not the only individuals that the Fourth Amendment applies to, but also to public school officials as they are agents of the states. Though they also held that students have an expectation of privacy at school, the expectation of privacy must be balanced against the needs of school authorities to provide an educational atmosphere. Because of this balance, school administrators do not need probable cause or a warrant prior to search a student at school. Instead, the legality of the search is determined by all the surrounding facts of the search.
In the Majority Opinion, written by Justice White, the Court created a test to determine reasonableness of a search. A search is reasonable if it was 1) justified at its commencement and 2) the search was reasonably linked to the current events that justified the intrusion at the beginning. In relation to T.L.O.’s case, the Court established the search was justified at its inception as T.L.O. was in violation of the school’s smoking policies. Secondly, the Court stated that finding the rolling paper justified the further search of her purse. Thus, the Court ruled that the school administrator’s search of T.L.O.’s belongings was constitutional and did not violate the Fourth Amendment.
Justice Blackburn wrote a concurrence with the majority opinion. He stated that school authorities responsibility for keeping the students safe and ensuring an educational atmosphere justifies an immunity from the Fourth Amendment’s requirement for probable cause and a warrant.
Justices Brennan, Marshal, and Stevens concurred in part and dissented in part. Justice Brennan and Justice Marshal specified the Fourth Amendment also applies to public school officials, but they should be able to search students without a warrant. However, they differed from the Majority Opinion in stating that reasonable suspicion should be the test for determining which searches are constitutional. Justices Brennan and Marshal expressed that probable cause should be the standard. Thus, with this standard, the school administrator did violate T.L.O’s rights and the evidence should not been admitted into court. In Justice Stevens’ concurrence and dissent in part, he indicated the search by the administrator was not reasonable at its start because there was no evidence T.L.O’s purse had evidence of a crime or violation of school policies. He argued the search was unconstitutional and the evidence should have not been admitted into court.
The Supreme Court’s ruling in New Jersey v. T.L.O. is precise for the circumstances surrounding the case. T.L.O. was found smoking in a school bathroom by a teacher, which was a violation of school policies. This event lead to the a search of her purse and the discovery of cigarettes and rolling paper, which then lead the administrator to believe T.L.O was smoking and/or selling drugs. A further search revealed this evidence, and later she admitted to selling marijuana. The test to determine the constitutionality of a search and seizure was created by the Supreme Court to better resolve vagueness in the Fourth Amendment. This test is valuable for police officers, public school administrators, and judges, in which it aids them in determining whether the state agent has the authority to search an individual and/or their belongings. The Court’s establishment of this test is a useful tool for many future Fourth Amendment cases.
In 1985, the Supreme Court was faced with another Fourth Amendment case. In New Jersey v. T.L.O., T.L.O. was found delinquent in juvenile court for possession of marijuana. The Supreme Court established a test to help determine the constitutionality of public school administrator’s searches and seizures of students. When T.L.O’s case is applied against the test, the majority of justices ruled that the school administrator’s search was constitutional, and T.L.O. had been delinquent. All levels of courts will continually be faced with the difficulty of deciding constitutionality of cases regarding the Fourth Amendment, such as New Jersey v. T.L.O.