Board of Educ. of Ind. School Dist. No. 92 of Potawatomie City v. Earls (2002)
Facts: A school district in Tucumseh, Oklahoma adopted a drug test policy which required all middle and high school students to consent to a drug test as a condition to participating in any extracurricular activity (Board of Educ. v. Earls, 2002, p. 826). The policy has only been applied to extracurricular activities that are competitive in nature, such as athletics and others sanction by the Oklahoma Secondary Schools Activities Association. Pursuant to the policy, students wishing to participate in extracurricular activities must submit to drug tests before participation, are subject to random drug testing, and must agree to testing at any moment upon a reasonable suspicion (Board of Educ. v. Earls, 2002, p. 826). The purpose of such drug testing is to detect the presence of illegal drugs.
Respondent high school students brought challenge against the school drug testing policy under the Fourth Amendment. The District Court granted summary judgment for the school district, finding no Fourth Amendment violation. The District Court specifically noted the “special needs” of the public school combat to combat the epidemic drug problems that exist among high school students (Board of Educ. v. Earls, 2002, p. 827). The Court of Appeals reversed the District Court, holding that the drug policy did violate the Fourth Amendment. The US Supreme Court granted certiorari to hear the case in 2001.
Issue: The issue in this case is whether the school’s coercive drug testing policy for students participating in certain extracurricular activities violates the Fourth Amendment.
Rationale: The Court pointed to a number of reasons why the drug testing policy was constitutional. First, the extent that the drug testing policy intruded into students’ constitutionally protected privacy interests was minimal (Board of Educ. v. Earls, 2002, p. 832). The Court was quick to point out that students are entitled to a lower level of privacy in public schools. Schools must be able to maintain safety, order, and discipline in the schools, which necessarily means that students do not have the same expectation of privacy in the school setting as in other places. In addition, extracurricular activities are subject to a variety of rules and regulations, and those students wishing to participate in such activities have a limited expectation of privacy (Board of Educ. v. Earls, 2002, p. 832).
The Court also looks to the limited use of the drug testing results for support that the privacy invasion is minimal. Results of the drug tests must be kept in separate files and are only made available to school personnel on a “need to know” basis (Board of Educ. v. Earls, 2002, p. 833). In addition, the results of the drug tests are not divulged to law enforcement, nor do the results lead to academic consequences of disciplinary matters for students.
Finally, the Court considered the strong government interest that the drug testing policy was intended to address. Preventing drug use and abuse among the nation’s youth is an important objective for public schools (Board of Educ. v. Earls, 2002, p. 834). The Oklahoma School District presented specific evidence that drug abuse was a problem in its schools, and the Court is deferential to the School District’s conclusions and response to the problem.
Vote: The vote was a 5-4 majority. The majority of the Court found that the drug testing policy was constitutional. The dissent disagreed and found that the drug testing policy was unreasonable and, therefore, violated the Fourth Amendment.
References
Board of Educ. of Ind. School Dist. No. 92 of Potawatomie City v. Earls, 536 U.S. 822 (2002).
