Safford usd v redding. Safford Unified School District v. Redding 2022-12-07
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Safford USD v. Redding is a landmark Supreme Court case that dealt with the issue of search and seizure in the context of public schools. The case arose after Savana Redding, a 13-year-old student at Safford Middle School in Arizona, was strip searched by school officials in 2003. Redding had been suspected of possessing ibuprofen, an over-the-counter pain medication, which was prohibited by the school's zero tolerance policy on drugs.
The search was conducted by school officials, including the school nurse, in a private room, and involved Redding being required to remove her clothes and expose her breasts and pelvic area. No drugs were found during the search. Redding and her mother filed a lawsuit against the school district, alleging that the search violated her Fourth Amendment rights, which protect against unreasonable searches and seizures.
The case made its way to the Supreme Court, which heard oral arguments in 2009. In a split decision, the Court ruled in favor of the school district, stating that the search was reasonable given the circumstances. The majority opinion, written by Justice David Souter, argued that the search was justified because the school had a legitimate interest in keeping drugs out of the school and that the search was not excessively intrusive.
However, the dissenting opinion, written by Justice Ruth Bader Ginsburg, argued that the search was unreasonable and violated Redding's Fourth Amendment rights. Ginsburg argued that the school officials had insufficient evidence to justify the search and that there were less intrusive means available to them to address the issue of drugs in the school.
The decision in Safford USD v. Redding has significant implications for the rights of students in public schools. The ruling establishes that school officials have the authority to search students when they have reasonable suspicion that the students are in possession of drugs or other contraband. However, the ruling also makes it clear that the scope of such searches must be reasonable and not excessively intrusive.
Overall, the decision in Safford USD v. Redding highlights the balance that must be struck between the need to maintain a safe and drug-free environment in schools and the need to protect the constitutional rights of students. While the Supreme Court's ruling in this case may not be popular with some, it is an important reminder of the importance of upholding the principles of the Fourth Amendment and the need to ensure that searches are reasonable and not excessively intrusive.
SAFFORD UNIFIED SCHOOL DIST. #1 v. REDDING
By doing so, the majority has confirmed that a return to the doctrine of in loco parentis is required to keep the judiciary from essentially seizing control of public schools. Nothing the Court decides today alters this basic framework. School officials discovered nothing in the search. Supreme Court had just heard oral argument. Safford unified school district v. Thirteen-year-old Savana Redding, an honor roll student with no prior disciplinary problems, was required to strip, exposing her breasts and pubic area, in a fruitless search for-at worst-prescription strength ibuprofen.
SAFFORD UNIFIED SCHOOL DISTRICT #1 ET AL. v. REDDING
. We think that the combination of these deficiencies was fatal to finding the search reasonable. This approach directly conflicts with T. The Court reaches a contrary conclusion about qualified immunity based on the fact that various Courts of Appeals have adopted seemingly divergent views about T. Marissa did so, producing one blue pill, several white pills, and a razor blade.
[Safford Unified School District v. Redding] Reaction
Although this presents considerable analytical tension, we can manage the difficulty by adopting some general rules. Thus, in order to locate a rationale for finding a Fourth Amendment violation in this case, the majority retreats from its observation that the school's firm no-drug policy "makes sense, and there is no basis to claim that the search was unreasonable owing to some defect or shortcoming of the rule it was aimed at enforcing. See ante, at 7. More than that: it is a violation of any known principle of human dignity. There, a disinterested student provided a tip to a teacher that Phaneuf, a student with a history of disciplinary problems, planned to stuff marijuana down her pants that day to take along with her on the senior class picnic. There is little question that a search of Savana's backpack and her pockets would be constitutionally permissible, given that Savana's friend and classmate Marissa had reported that Savana had provided her with the ibuprofen. See Williams ex rel.
If Marissa knew that Redding actually had no pills, she also would have known that a search would have turned up nothing. Even accepting the majority's assurances that it is not attacking the rule's reasonableness, it certainly is attacking the rule's importance. Let us be realistic: Had Wilson not acted swiftly and decisively, and had a child fallen ill, the community would have been outraged by the school's laxity. Courts recognizing those situations would be wise to take the time to resolve the constitutional question. An Aleve caplet contains 200 mg naproxen and 20 mg sodium. In my view, qualified immunity is available because the law heretofore did not give adequate guidance to the school officials.
He asked Savana if she knew anything about the pills. Jimeno, United States v. The reasonable suspicion that Redding possessed the pills for distribution purposes did not dissipate simply because the search of her backpack turned up nothing. Wilson had reason to connect the girls with this contraband, for Wilson knew that Jordan Romero had told the principal that before the dance, he had been at a party at Savana's house where alcohol was served. Frederick, New Jersey v.
But nondangerous school contraband does not raise the specter of stashes in intimate places, and there is no evidence in the record of any general practice among Safford Middle School students of hiding that sort of thing in underwear; neither Jordan nor Marissa suggested to Wilson that Savana was doing that, and the preceding search of Marissa that Wilson ordered yielded nothing. Schools have a significant interest in protecting all students from prescription drug abuse; young female students are no exception. Saucier, See Drummond ex rel. Here, the content of the suspicion failed to match the degree of intrusion. The assistant principal took the pill to the school nurse who identified it as prescription-strength 400-mg Ibuprofen. As one study noted, "more young people ages 12-17 abuse prescription drugs than any illicit drug except marijuana--more than cocaine, heroin, and methamphetamine combined. The shaking failed to dislodge any pills.
More important is the fact, apparently unrecognized by the school officials, that to force a teenage girl to strip upon school command would lead to an embarrassment of her that could cause deep and lasting psychological harm. He was the only student suspected of the same infraction that day not required to strip for the school officials' inspection. For those reasons, we can encourage school officials to show compassion by involving parents in the searching and questioning of students. The reasonableness of her expectation required by the Fourth Amendment standard is indicated by the consistent experiences of other young people similarly searched, whose adolescent vulnerability intensifies the patent intrusiveness of the exposure. The measures adopted in this case were reasonably related to finding ibuprofen.
Safford Unified School Dist. #1 v. Redding :: 557 U.S. 364 (2009) :: Justia US Supreme Court Center
The search under review easily meets this standard. Blackstone, Commentaries on the Laws of England 441 1765 "He may also delegate part of his parental authority, during his life, to the tutor or schoolmaster of his child; who is then in loco parentis, and has such a portion of the parent committed to his charge, viz. Nevertheless, we must not demand that school officials present too much independently corroborated evidence from unquestionably reliable sources; we must ensure that even highly intrusive searches do not stand or fall on the presence of probable cause. Asked next "who is she? Savana's actions in their presence necessarily exposed her breasts and pelvic area to some degree, and both subjective and reasonable societal expectations of personal privacy support the treatment of such a search as categorically distinct, requiring distinct elements of justification on the part of school authorities for going beyond a search of outer clothing and belongings. The initial search of Savana's backpack which, like T.
Furthermore, in evaluating whether there is a reasonable "particularized and objective" basis for conducting a search based on suspected wrongdoing, government officials must consider the "totality of the circumstances. These constitutional principles were clearly established by the United States Supreme Court twenty years before the Safford school officials conducted the strip search of thirteen-year-old Savana. See Williams, Importantly, Wilson was not searching for evidence of past ibuprofen use, such as an empty Advil bottle. Seeking to reconcile the Fourth Amendment with this unique public school setting, the Court in T. See ante, at 8—10; see also ante, at 1 Ginsburg, J. To determine whether to believe the denial, the vice principal brought T. Redding also acknowledged a friendship between Marissa and herself during her interview with Wilson.
One week later, Romero handed the assistant principal a white pill that he said he had received from Glines. Under the resulting reasonable suspicion standard, a school search "will be permissible. As it turns out, there are multiple T. Finally, Savana was told to pull her bra out and to the side and shake it, and to pull out the elastic on her underpants, thus exposing her breasts and pelvic area to some degree. The lesser standard for school searches could as readily be described as a moderate chance of finding evidence of wrongdoing. Savana agreed to this search. In contrast to the Supreme Court's recent school search cases, the majority fails to acknowledge the unique considerations present in the public school setting, including the need for informal and flexible disciplinary measures, and the considerable risk presented by drugs.
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