New Jersey v. T.L.O (1985): Facts and Case Summary

Administrative Office of the U.S. Courts

T.L.O was a student at a New Jersey high school. A teacher found T.L.O and another student smoking cigarettes in the school restroom and brought the two students to school administration. When questioned, one student admitted to smoking, but T.L.O. denied the allegations. The administrator demanded to search T.L.O’s belongings to find cigarettes. Upon searching through T.L.O’s purse, the administrator found cigarettes and cigarette rolling paper and now suspected T.L.O. of smoking marijuana as well as cigarettes. The administrator also found a small bag with a grass-like substance, a pipe, cash, and a list of students who owed T.L.O money. The administrator then called the police, and the police called T.L.O’s mother. T.L.O. confessed to selling marijuana at the police station.

T.L.O. faced delinquency charges in Juvenile Court. The Court denied T.L.O’s motion to keep the confession and evidence from the search out of the proceedings. T.L.O was found delinquent and appealed the case to the U.S. Supreme Court. The Supreme Court’s majority decided that the Fourth Amendment’s prohibition on unreasonable searches and seizures is not limited to police and other members of law enforcement–it also applies to public school officials. However, school officials do not need to obtain a warrant to search a student’s belongings when the need to maintain an appropriate educational environment is greater than the student’s right to privacy.

The Supreme Court established a test: was a search justified at its inception? Or was it reasonably related in scope to the circumstances that justified the search in the first place? According to the Supreme Court, T.L.O’s search was justified at its inception given the teacher’s report of T.L.O smoking and violating school rules which allowed for a reasonable suspicion that T.L.O. had cigarettes.

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